Press Center

Common Cause Letters

 

 

 

 

January 3, 2012

 

Ms. Elizabeth M. Murphy

Secretary

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.   

Sincerely,

 

Corporate affiliations for identification purposes only

 


 

PRIVATE COMPANIES

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


 

 

 

PUBLICLY HELD COMPANIES

 


 

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.


 

 

 

INVESTMENT FIRMS

 


 

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


 

 

SELF REGULATORY ORGANIZATION


R. Warren Langley
President (Ret.) Pacific Stock and Options Exchange

 

 

LAW FIRMS/ATTORNEYS

 


 

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