Ms. Elizabeth M. Murphy
Securities and Exchange Commission
100 F Street, Northeast
Washington, D.C. 20549
Re: COMMITEE ON DISCLOSURE OF CORPORATE POLITICAL SPENDING PETITION FOR RULEMAKING (August 3, 2011), File No. 4-63
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
President, Real Estate Directions, Inc.
President, The Golden Ribbon, Ltd.
CEO (Ret.), FPG Photo Archive; Director, New Economics Institute
Vice President, Real Estate Directions, Inc.
Allan F. Brown
Chairman & CEO (Ret.), Vance Brown, Inc.
Julie & Bob Carter
Founders, Fresh Samantha Beverages
President, Pacific Gourmet Inc.
Craig C. Darian
Co-Chairman & CEO, Occidental Entertainment Group Holdings
President, CheckPoints LLC
John H. Elliott
President, South Carolina Elastic Co.
Chairman, EFO Capital Management, Inc.
CEO (Ret.), Phoenix Computers Associates
Wild Planet Entertainment
F. Barton Harvey
CEO (Ret.), The Enterprise Foundation
Leonard Hill Films
Worldwide Publisher Runner's World and Publishing Director Men's Health (ret.)
William N. Hubbard
President, Center Development Corporation
President, Public Interest Pictures
CEO, LibraryWorld, Inc.
Chairman, Act III Communications
President (Ret.), Bustin Industrial Products
Peter L. Malkin
Chairman, Malkin Holdings LLC
Chang K. Park
Chairman of the Board, Universal Remote Control
Co-Founder, Innovative Interfaces Inc.
Executive Producer, Whitewater Films
Co-Chairman, Occidental Entertainment Group Holdings
PUBLICLY HELD COMPANIES
Peter A. Benoliel,
Chairman Emeritus. Quaker Chemical Corporation
Vice President (Ret.), Cisco Systems
Frank A. Butler
President (Retired) Eastman Gelatine Corporation (a Kodak subsidiary)
Co-Founder, Ben & Jerry's
Roger L. Hale
Chairman & CEO (Ret.), The Tennant Corporation
Retired Chairman and CEO, Hasbro, Inc.
Chairman & CEO (ret.), Stride Rite Corp.
President and CE-Yo, Stonyfield Farm, Inc.
Honorary Chairman, Automatic Data Processing Inc.
Chairman & CEO (Ret.), At-a-Glance; Founder, Cullman Ventures
Director of Corporate Responsibility, Social Equity Group
Managing Director, Alta Partners; CEO, Nanomix
Leo Hindery, Jr.
Managing Partner, InterMedia Partners, LP
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
President & CEO, Pax World Management LLC
Partner, August Capital
Founder, Managing Member, Skyline Public Works
Chairman, Schooner Capital
SELF REGULATORY ORGANIZATION
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