November 10, 1997
     
     
Jonathan G. Katz, Secretary
Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C. 20549
     
Dear Secretary Katz,
     
We would like to offer the following comments on the Commission's request 
on Charitable Giving by Public Companies.  These comments come from 
discussions we have held with some of our national and regional officers 
and are not the result of an extensive survey.  These are people in regular 
touch with many of our nearly 700,000 members.
     
It was the feeling that the decision to give corporate money and the amount 
to be given and the timing was a management decision.
     
It was felt that management should be free to determine where a certain 
amount of the giving went particularly if a matter of corporate interest 
was involved, but that the greater amount be determined by shareholders. 
It was not felt that shareholders should vote on particular gifts.  It was 
felt that half to two thirds of corporate giving should be in the form of 
gifts that matched shareholders and employees gifts in whole or in part. 
It was felt that currently a number of corporations match the gifts of 
employees.  Since the money disbursed is more rightfully the property of 
shareowners, it would seem that that privilege should be theirs.
     
The amount of corporate gifts should be disclosed in the Annual Report 
along with the names and amounts given to the top five to ten recipients.
     
The complete list of gifts and recipients should be available on 
shareowner's request.  In this report the corporations' policy of matching 
gifts should be publicized.
     
These comments are a little different form those expressed at the Consumer 
Affairs Advisory Committee and I thought you might appreciate them.  They 
are ideas expressed by people who are individual shareowners as well as 
representing a very large number of them.
     
Best wishes,
     
     
Thomas E. O'Hara
Chairman, Board of Trustees
     
_________________________________
     
Sue Peterman            NAIC
     
suep@better-investing.org
248.583.6242x303
     
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