1401 Fairway Drive
Marshalltown, Iowa  50158
(515) 752-8775
November 8, 1997
     
TO:  US Securities and Exchange Commission
RE:  File No. S7-26-97; Commentary on HR 944 and HR 945; Charitable Giving by 
Public           Companies
     
Ladies and Gentlemen:
     
I appreciate the opportunity to comment on the above pending legislation.  I 
have little knowledge of the business world, but have spent the past nine 
years seeking better accountability to the public from the non-profit arena.
 I believe that disclosure to  stockholders of charitable contributions made
by public companies has the potential to be of great benefit in this regard, 
and could serve to avert unwanted regulation.  My effort and concern have been 
concentrated on one of our nation's largest health charities, but I believe my 
observations to date might well be extrapolated to some other members of the 
non-profit community and may be of concern to corporations and their 
stockholders.
     
In regard to HR 944:
     
I strongly agree with the proposal to require disclosure of corporate 
charitable and other contributions as described in the bill.    I have some 
concerns about the exemptions, as follows:
     
a.  I believe gifts of tangible personal property, perhaps above a certain 
minimum value, should be disclosed to stockholders.  If I am interpreting 
this correctly, I can envision contributions of - say - a fleet of vehicles 
to a charity, which this exemption might conceal.
     
b.  I can see no reason why gifts to nonprofit educational institutions 
should not be disclosed to stockholders.
     
c.  I can agree with non-disclosure of small contributions to local 
charities.  I believe a clear definition of "local" is needed, however.  In 
the case of some of our nation's large charities, which may have state or 
regional divisions/affiliates and county-based units, I have often seen the 
erroneous claim that all donations will be used "locally."  The implication 
here has been that "local" equates to the community or immediate area.  In 
fact, with the charity I am concerned with, such "local" donations all go 
directly to the state division.  Of this, almost half is sent on to the 
national organization and an unknown portion thence to support its 
international organization.  No accounting whatever is made to the public of 
the charity's international expenditures or income.  
        I am sure the intent of this exemption relates to contributions meant
for
the benefit of a given community or local area.  A problem exists when a 
national charity implies incorrectly that its community fundraising unit is a 
"local" organization which strictly benefits the local area.  A clear 
definition of "local" would help.
     
I would like to provide a few examples to demonstrate how I feel corporate 
disclosure of charitable giving might benefit the public at large:
     
1.  The "independent" auditor of the referenced charity's state, national, 
and international organizations is one of the charity's major, regular 
contributors.  Routine disclosure of this relationship might give a more 
realistic perspective to the auditing firm's stockholders.
     
2.   Allegations were reported by the media in another state that a public 
relations firm had donated a certain sum to this charity, with the 
understanding that the charity would use its influence with the state 
legislature to award the PR firm a $14 million anti-tobacco advertising 
contract.  The PR firm won the contract, and the whistle-blower reportedly 
"settled" for an unknown sum with the charity, then dropping the charges.  If 
I were a stockholder with this firm, I would want complete disclosure of its 
charitable contributions.
     
3.  The government of one state has contracted (I have the document) to pay 
the referenced charity over a million dollars annually in exchange for the 
use of its logo in promotion of one of the state's products.  The charity 
often claims in solicitations that it receives no government funds, and is 
describing this arrangement in print and on the airwaves as a "corporate" 
donation.  Routine disclosure of corporate donations might assist the public 
in recognizing this type of deception.
     
4.  One corporation holds fundraisers once annually for the charity, at 
perhaps two dozen sites across the country.  The company promotes the events' 
purpose as being to raise funds for the charity for a specific type of 
disease research,  mentioning no other purpose.  Coincident with the 
corporation's statements about the specific purpose of the fundraiser, press 
releases from the charity's national headquarters state - variously - that 
the proceeds will be used (a.) locally in each community hosting the 
fundraiser or (b) as a general donation to benefit all the charity's programs 
nationwide.  No mention is made by the charity of using them for the purpose 
that the corporation describes.  Disclosure to stockholders might help expose 
such deception.
     
In regard to HR 945:
     
At first glance, I felt that allowing shareholders a proportionate say in the 
designation of charitable contributions was an excellent idea.  On further 
consideration, I do wonder if harrassment of large shareholders by 
innumerable charities might not be the result.  I am ambivalent here.
     
        Thank you for your attention.  If documentation of any of the examples
above
would be helpful, please let me know.
     
Sincerely,  Karen Packer