Date:    11/18/97  1:07 PM

Subject: File No. S7-26-97 / New York Public Library

     November 10, 1997
     
     Jonathan G. Katz
     Secretary
     US Securities and Exchange Commission 450 Fifth Street, NW 
     Washington, DC  20549
     
     Re: File No. S7-26-97
     
     Dear Secretary Katz:
     
     Thank you for giving charitable institutions the opportunity to 
     comment on proposed legislation that would amend the SEC Act regarding 
     disclosure of charitable contributions.  Although The New York Public 
     Library has no objection to HR944, we are very concerned about HR945 
     and the impact it would have on philanthropic giving to charitable 
     organizations.
     
     The New York Public Library (NYPL) is a not-for-profit organization 
     that serves 15 million individuals each year through four research 
     libraries and 85 branch libraries in every neighborhood in the Bronx, 
     Manhattan and Staten Island. Last year, corporations supported 
     approximately three percent of the NYPL's total budget, and more than 
     five percent of The Research Libraries' budget.  Corporate giving 
     supports a wide variety of programs, including the purchase and 
     cataloging of new materials for the Library's collections, the 
     preservation of brittle books and materials to make them available for 
     future generations of scholars, the training of staff in new 
     technologies, and the mounting of interpretive exhibitions visited by 
     thousands of individuals annually. Many of the corporations that 
     support NYPL have done so for twenty or more years, have developed a 
     close working relationship with the Library's staff, and understand the 
     needs of the Library for both special project support and funding for 
     general operations.
     
     HR945 is very threatening to charitable institutions and would result 
     in decreased corporate support for charities. Corporate Philanthropy 
     Officers are experts in their fields, have developed clear funding 
     priorities and guidelines for the charities eligible under these 
     priorities to receive corporate support, and work closely with 
     charities to implement their funding priorities over a period of 
     years. Requiring a corporation to gain consent from shareholders 
     before making any corporate contributions would use additional time 
     and money that a corporation may not be willing to spend on 
     contributions, and would subject charities to the whim of 
     shareholders, who may change frequently. Although there are many ways 
     to adopt this disclosure system, all would require significant changes 
     in corporate philanthropy and would add layers of bureaucracy to the 
     system.  The net result would be a reduction in corporate charitable 
     contributions.  
     
     I urge you to let the Commerce Committee's Subcommittee on Finance 
     and Hazardous Materials know that HR945 is simply not feasible and is 
     not in the best interest of corporations, charitable institutions, or 
     the shareholders.  
     
     Sincerely yours,
     
     Paul LeClerc
     
     
     (Sent by Jung H. Yun, Executive Assistant to the President. Signed 
     hard copy will be mailed.)