December 15, 1997 Jonathan G. Katz Secretary U.S. Securities and Exchange Commission 450 Fifth Street Washington, DC 20549 Dear Secretary Katz: You have requested public comment on H.R. 944 and H.R. 945 and I am writing to express my opposition. Our bank is the largest private donor in the state of Alaska. I can assure you that this bill would have a negative effect on our level of giving. We are not in the business of publicizing our donations or seeking recognition. We believe that philanthropy is good business. We believe that our company management is in the best position to assess which contributions to make and we expend a significant number of dollars each year in support of staff whose job is to review the many requests for support we receive. The proposed legislation would cause corporations to spend dollars that would otherwise be used for charitable contributions on needless administrative work. This is not good public policy. H.R. 944 and H.R. 945 may be well-intentioned but would have the effect of reducing corporate contributions to worthy non-profit organizations. In a time of shrinking government support for the arts, health and social services, and education, it would be ill-timed to initiate legislation that would reduce the availability of private support for such needs. Edward B. Rasmuson Chairman National Bank of Alaska