I urge you to approve the proposed rule in File Number 4-637 that would require publicly traded corporations to disclose their political spending to their shareholders.
This proposed rule benefits both corporate shareholders and the public at large and is consistent with existing rules governing publicly traded corporations that already require disclosure to current and prospective shareholders of a variety of internal corporate data, such as earnings, assets, executive compensation, and litigation.
So long as corporations are allowed to allocate shareholder resources to support political activities, shareholders should have the right to know the distribution of these funds. This allows investors both to make principled choices about whether they want their assets deployed for such ends as well as to make informed investment decisions with regard to the market risks to which such political spending may expose them, risks engendered by public persuasion and boycott campaigns frequently launched against companies in reaction to their political activities. Just as with current shareholder disclosure requirements, the information transparency provided by this proposed political spending disclosure rule is vital to protecting investors and promoting efficient markets.
In addition, proposed rule 4-637 also offers a broader benefit to the public in closing a loophole in the U.S. political campaign regulatory framework which was opened by the Citizens United v. FEC decision by the U.S. Supreme Court that permits political spending without disclosure. This dangerous loophole allows corporations to pursue self-interested political ends in secret. Their enormous concentrated spending power relative to the distributed and uncoordinated political spending potential of the vast majority of private citizens allows corporations to achieve effective regulatory capture, to the detriment of free markets and the public good.
Thank you for approving proposed rule 4-637, which puts at least one check on the undue influence of monied corporate interests in our political process by making corporate political spending open and transparent to shareholders and consumers.