Committe on Disclosure of Corporate Political Spending Petition for Rulemaking

January 3, 2012

Ms. Elizabeth M. Murphy


Securities and Exchange Commission

100 F Street, Northeast

Washington, D.C. 20549


Dear Ms. Murphy:

Transparency and honesty are the foundation of any free market. Without those principles, investors cannot have trust in the marketplace. That is why we, as business leaders, are writing to support the petition for rulemaking that would require greater transparency of corporate political spending.

We are troubled by the way that some of our business colleagues have chosen to exploit recent court rulings expanding the right of companies to participate in politics. Rather than donate openly and deal honestly with shareholders and citizens, these firms fail to adequately disclose campaign expenditures from their corporate treasury.

We agree with the eight Supreme Court justices who, in last year's Citizens United decision, said that disclosure allows shareholders to "determine whether their corporation's political speech advances the corporation's interest in making profits." Shareholders can only make that determination if the corporation where they have an equity interest fully discloses their political expenditures. That is why it is critical for the Securities and Exchange Commission to enact a rule to require corporations to disclose political spending to shareholders, not only to protect shareholders but to strengthen the corporations themselves.

It is exactly this type of disclosure that facilitates good corporate governance by encouraging corporations to create a process in which these types of donations are thoroughly evaluated. As Minnesota-based Target Corporation saw in 2010, these types of political donations can come with a risk to the corporation's reputation and shareholder value. Political disclosure can help shareholders, management and directors deal with the risks associated with political spending of treasury dollars.

We strongly believe that requiring disclosure of corporate political spending will strengthen the way that corporations operate and will protect the investment of shareholders.


Corporate affiliations for identification purposes only


Aris Anagnos

President, Real Estate Directions, Inc.

Susan Bonner

President, The Golden Ribbon, Ltd.

Jessica Brackman

CEO (Ret.), FPG Photo Archive; Director, New Economics Institute

Lydia Brazon

Vice President, Real Estate Directions, Inc.

Allan F. Brown

Chairman & CEO (Ret.), Vance Brown, Inc.

Julie & Bob Carter

Founders, Fresh Samantha Beverages

John Cawley

President, Pacific Gourmet Inc.

Craig C. Darian

Co-Chairman & CEO, Occidental Entertainment Group Holdings

Todd Dipaola

President, CheckPoints LLC

John H. Elliott

President, South Carolina Elastic Co.

Jim Epstein

Chairman, EFO Capital Management, Inc.

Larry Erdmann

CEO (Ret.), Phoenix Computers Associates

Daniel Grossman

Wild Planet Entertainment

F. Barton Harvey

CEO (Ret.), The Enterprise Foundation

Leonard Hill

Leonard Hill Films

George Hirsch

Worldwide Publisher Runner's World and Publishing Director Men's Health (ret.)

William N. Hubbard

President, Center Development Corporation

Lenny Mendonca

Earl Katz

President, Public Interest Pictures

Steve Kirsch

CEO, Propel

Norman Kline

CEO, LibraryWorld, Inc.

Norman Lear

Chairman, Act III Communications

Mark Lichty

President (Ret.), Bustin Industrial Products

Peter L. Malkin

Chairman, Malkin Holdings LLC

Chang K. Park

Chairman of the Board, Universal Remote Control

Steve Silberstein

Co-Founder, Innovative Interfaces Inc.

Nancy Stephens

Executive Producer, Whitewater Films

Albert Sweet

Co-Chairman, Occidental Entertainment Group Holdings


Peter A. Benoliel,

Chairman Emeritus. Quaker Chemical Corporation

Robert Burnett

Vice President (Ret.), Cisco Systems

Frank A. Butler

President (Retired) Eastman Gelatine Corporation (a Kodak subsidiary)

Ben Cohen

Co-Founder, Ben & Jerry's

Roger L. Hale

Chairman & CEO (Ret.), The Tennant Corporation

Alan Hassenfeld

Retired Chairman and CEO, Hasbro, Inc.

Arnold Hiatt

Chairman & CEO (ret.), Stride Rite Corp.

Gary Hirshberg

President and CE-Yo, Stonyfield Farm, Inc.

Josh Weston

Honorary Chairman, Automatic Data Processing Inc.


Lewis Cullman

Chairman & CEO (Ret.), At-a-Glance; Founder, Cullman Ventures

Ron Freund

Director of Corporate Responsibility, Social Equity Group

Garrett Gruener

Managing Director, Alta Partners; CEO, Nanomix

Leo Hindery, Jr.

Managing Partner, InterMedia Partners, LP

Mellody Hobson

President, Ariel Investments, LLC

Frederick S. Hubbell

Chairman (Ret.), Insurance and Asset Management Americas, ING Group

G. David Hurd

Chairman & CEO (Ret.), Principal Financial Group

Michael J. Johnston

Executive Vice President (ret.), Capital Group Companies

Joe Keefe

President & CEO, Pax World Management LLC

Andy Rappaport

Partner, August Capital

Deborah Rappaport

Founder, Managing Member, Skyline Public Works

Vincent Ryan

Chairman, Schooner Capital


R. Warren Langley

President (Ret.) Pacific Stock and Options Exchange


Douglas W. Dunham

R. Scott Greathead

Partner, Wiggin & Dana

Dana W. Hiscock

Partner, Patterson Belknap Webb & Tyler, LLP

Robert M. Pennoyer

Of Counsel, Patterson Belknap Webb & Tyler

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