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The Public Advocate for the City of New York

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The Public Advocate for the City of New York THE PUBLIC ADVOCATE FOR THE CITY OF NEW YORK Bill de Blasio - PUBLIC ADVOCATE January 27, 2012 Ms. Elizabeth M. Murphy Secretary, Securities and Exchange Commission (SEC) 100 F Street, NE Washington, D.C. 20549 By email: [email protected] Re: File No. 4-637, Petition to Require Public Companies to Disclose to Shareholders the Use of Corporate Resources for Political Activities Dear Ms. Murphy: We, the undersigned, represent a diverse community of concerned citizens. We are elected officials, shareholders, institutional investors, consumers, community organizers, nonprofit leaders, and much more. Whereas we have many differences among us, we share a view that openness is a core hallmark of a strong democracy and we, the undersigned, are all united in support of the pending petition before the SEC to require public companies to disclose their political spending to shareholders. According to recent research by the Sustainable Investments Institute and the IRRC Institute, voluntary corporate disclosure of political spending remains limited, with only 20 percent of S&P 500 companies reporting on how they spent shareowners' money. In addition, only 38 companies out of the entire S&P 500 mention independent expenditures, such as Super PAC contributions, as part of their policies on corporate political spending. We cannot and should not be left in the dark about the use of corporate treasury dollars in our elections. Now is the time to act. Two years ago, the Supreme Court's ruling in Citizens United v Federal Election Commission opened the floodgates on political spending in this country. With more than $4 billion in total spending, the 2010 election was the most expensive midterm election in U.S. history. This year's Presidential election will undoubtedly break records on election spending once again - with millions of dollars in undisclosed spending being channeled through anonymous contributions to trade associations, 501 c4 organizations and eventually Super P ACs. We ask that the Securities and Exchange Commission act quickly to consider the proposed rule on disclosure of corporate political spending. Transparency in corporate political spending is in the best interests of investors, companies and the general public, and we strongly believe that the Securities and Exchange Commission is the most appropriate agency to require such disclosure. Sincerely, Bill de Blasio Public Advocate for the City of New York 1 CENTRE STREET NEW VORK NY 10007 TEL 212 669 7200 FAX 212 669 4701 WWW.PUBADVOCATE.NYC.GOV ... ~/~0(~---> Margaret Chin Daniel Dromm New York City Council Member New York City Council Member df,;:/vS/j r Letitia James Brad Lander New York City Council Member New York City Council Member ~/£, Stephen Levin Melissa Mark-Viverito New York City Council Member New York City Council Member /fir;tIt: 6Pv4/N~ Deborah Rose v JiI#y Van Bramer New York City Council Member New Y oik' City Council Member ~rL- ;f(!,/, Daniel Squadron %~:ane Williams New York State Senator New York City Council Member SUSAN LERNER, EXECUTIVE DIRECTOR, TIl REVESZ, CHAIR, CITIZEN ACTION COMMON CAUSE NEW YORK OF NEW YORK CITY IVETTE ALFONSO KAREN SCHARFF, EXECUTIVE DIRECTOR, PRESIDENT, CITIZEN ACTION OF NEW YORK CITIZEN ACTION OF NY COALITION FOR ACCOUNTABILITY IN MAKE THE ROAD NY POLITICAL SPENDING (CAPS) GARY STRINGER, LAWTON, OK COLLEEN BROWN, LAS VEGAS, NV DAVID CHINI, NY DIANA ZAAVALA, NY ROBERTA MOORE CHARLES KITE, MENANDS, NY ZACH POFF, NY TERESA SIFFORD, EL DORADO, KS JOSH SILLS, NY KAREN BAKER, FRANKLIN, PA ANDY BELLAMY, NY LORINDA NIDAY, LEES SUMMIT, MO BARBARA BRENNER, NY LUIS HERAS, CANYON LAKE, TX DINAH BAZER, NY SUSAN WATKINS, BEND, OR JOE CONNORS, NY NICK CARSON, BETHANY BEACH, DE WILLIAM BILHARDT, CHERRY HILL, NJ RANDY OBERLANDER, NY MARCIA C REDDING, NEWTON, MA HOMER WOOD ANA MEDINA, NY MARGARET KELLER, RICHTON PARK, XL PETER STANKlEWICZ, NY WALTER TANNER, NY SCOTT LINK, NY KATHLEEN GRAHAM, KISSIMMEE, FL WENDELL GOODE GERARD BARIL, NEW YORK, NY JOEL MERKER, NY LARRY ASKEW, SCARSDALE, NY MAX ROSEN-LONG, PA DELROY KNOTT, ESTROUDSBURG, PA JESSICA KEATING, BROOKLYN, NY GERALD SYKES, CALVERT CITY, KY ALICE WOOD, , MA PAMELA SAH, NY SOPHIA WONG, NY SUSAN MCRAE, LONGWOOD, FL JEFFREY EICHE, NY TESSA CHANDLER, NY GEORGE CASTRO, NY GUNTER NITSCH, CHICAGO, IL MARISTELLA INNOCENTI, NY DAVID RICHARDS, STOCKTON, CA RICI-IARD HOLT, NY CAROLYN DUVALL, STATEN ISLAND, NY WAYNE FORGIE, DELTONA, FL HARRIET DAVIS-KRAM, NY DAVID RULE, NY ALAN REID, BELFORD, NJ JOHN HAMEL, FAIRFIELD, CT SHIRLEY L YSHOL, EDMONDS, W A DONNA REEVES, SUNSET, LA MICHAEL WEIN, GULF BREEZE, FL SHERI INMAN, HOLT, FL TINA SARTORI, PLANTION, FL MARJORIE AND LORENCE LONG, NY SARAH CALIMAN, NY STEVE EMERSON, PUYALLUP, W A ATHANAS lOS GALITSIS, NY ELLEN BESCHLER, NY PETRE SCAFARU, NY CAROL COMEAU, NY MARIO TROIANI KATE BENSON, NY SHERRY CALL, NY PHILLIP ROSENBERG, SANTA ROSA, CA HAROLD RAYBERN, PIQUA, OH JOOST YFF, ESTERO, FL SUSAN CZUPOWSKI, FALL CREEK, WI CASEY HALE, NY NADINE MYERS DENNIS SLADE, NY ROB FRIEDMAN, NY MARCIA HUNTINGTON, OCEAN SHORES, W A PETER POTTINGER ALICE CONNORTON, NY JOHN CATHERINE, NY ANNE FERGUSON, WINTHROP HARBOR, SHIV CHIN, NY IL EVA LABONTE, BETHPAGE, NY MICHAEL KILPATRICK, BURSON, CA CHARLES TIFFANY, STREET, PA DAVID ECHT, AUSTIN, TX TONIA PORRAS, NY ROBERT LEWIS, NY JERRY MULLIGAN, TEMPE, AZ SANDRA MARTINEZ, NY LHOU, NY CARLOTTA CUNDARI, TOANO, VA CHERYL SINNI, NY JOAN FERRANTE, NY ABIGAIL COSTELLO, NY TAYLOR HARBISON, HANOVER, PA CAROLYN WEMBER, NY KATHERENE BATES, MILTON, FL ESTHER LOUISE, NY ALFRED TRUJILLO, FE, NM PATRICIA VORDERSTRASSE, LEBANON, JARED GREENFIELD, NY OR MICHELLE BURNS, RNERDALE, MD MARVIN WICKWARE, NY JANE WILCOX, ALGER, OH JULIE FISSINGER, NY PATRICIA C. TOWERS, NY PATRICIA KNUTSON, TUCSON, AZ LAURA DAIGEN-AY ALA, NY SHIRLEY THOMPSON, NY DAVE NAJJAR, NY JUANITA MAYS, MILFORD, OH GABRIEL BOBEK, NY FRED WEIDENHAMMER, NY ELEANORA TEVIS, NY MEG MAZZEO, NY RUTH BOYD, NEEDHAM, MA JADE MONAI-lAN, NY KATHERINE O'SULLNAN, NY SUZANNE WYATT, BRADENTON, FL JAMES GREENWOOD, NY ISMET KIPCHAK, NY JOSEPH MORRIS V. RADOLINSKJ, NY REBECCA STUMPF, NY JOHN HOLLICK, NY JOAN FARBER, NY CRAIG CORBETT, SACRAMENTO, CA LESLIE KOGOD, NY ALICE KJELLGREN, NY ROBERT BANOV, NY MIKE ROMANO, NY ANGELIKA WINNER, NY MICHELLE SOMERS, NY MARLENE BLOSS, DUNEDIN, FL RADAMES LOPEZ, NY ROSEMARY DALESSANDRO, NY BILL LAWSON, BOISE, ID ETHAN GETO, NY JOHN MCGINNIS, PETALUMA, CA JAVIER GARCIA COLIN PEARCE, NY CAROL DOBSON, NY JAMES TATE, NY DAVID HALBERT, CONCORD, CA BOBBY APPLEWI-lITE, AZLE, TX SEAN GALLAGHER, NY JIM PROTOS, NY RACHEL RIPPY, NY ASHTON BARFIELD, NY LUMALPIEDE KESHAV BAGGAN, NY NATASHA HOLIDAY, BROOKLYN, NY DON MOHLER, PHOENIX, AZ ELAINELENZ ANDREW PEASE, NY GERALD LARSON, KEWANEE, IL MARK CARACO, HULL, MA MELINDA MALDONADO, NY MICHAEL ODONNELL GILLIAN FRASIER, NY MARlA LITTLE, QUEENS, NY ANDREW CORBO, NY SUZANNE G., NY PATRICIA DUNBAR, JERSEY CITY, NJ GERRY KELLY, SANTA FE, NM LAWSON SHADBURN, NY CHRISTINA STRINGER, LAWTON, OK STEVE MCGREGOR, CHANTILLY, VA SUSAN DENNICK, MANALAPAN, NJ TTAlANAPAHLEN, NY CAROL GUASTI, NY JEFFREY PRANT, NY SONJA HOLDER, NY DAVID FRANKLIN, BROOKLYN, NY NATASHA CHERNY, STAMFORD, CT MR. ELDER ROMEL VIEL, BROOKLYN, ANTON FEOKHARI, NY NY JOHN GALITSIS, NY HENRIETTE OHNO, NY PEMBERTON ROACH, NY TERISALCI SANDYE RENZ, BKLYN, NY HELEN CHOI, NY BARBARA DUVAL, NY STEVE LEVINESTEVEL, BROOKLYN, NY JOHN ROACH, NORTHVILLE, MI MIKE HANSEN, LEVITTOWN, NY PATRICK MCNULTY, NY NINA FRIEMAN, NY BEVERLY BELL, WILM, DE HARLAN BUSH LINDA ROSENBLATT ISAAC PURDUE, NY ANDREA COUTURE, NY CURTIS INOUE, NY SUZANNE BAGLEY, NY NANCY AMBRUSTER, NY WALLACE BERGER, NY KIYOSHI KANAI, NY LESLIE BRUMER, WOODLAND, CA CAROL DIAZ, NY CAY THOMSEN, VANCOUVER, W A DEBRA SFETSIOS, NY DOUGLAS MANFREDI, NY JOHN WEIDENBUSCH, NY ROBERT GRAHAM, KISSIMMEE, FL DAVID COURT, NEW YORK, NY EVA LANDEO, NY MINA JONES, NY ATHENA GALITSIS, NY ELOISE HOLLEN, PHILIPPI, WV G.L. TYLER, NY KEITH WILLIAMS, TONAWANDA, NY MARGARET GILPIN, NY TOBY HOROWITZ, NY EDEFOX FRANCES DELLACAVA, NY JULIE FOTHERINGHAM, NY BETTY GERENDASY, NY JAMES MILLER, V AIL, AZ EVERETT WILLIAMS, NY JACKIE BUNNELL, MADISON, WI ANITA FELDMAN, NY NANCY CAUTHEN, NY RICHARD CURRIE, NY MICHAEL GNAT, NY JOHN RICHARDSON, BURLEY, W A STEVE SCARPETTI, P A WT, RI GAIL DASHER JOE FOSTER, NY SHARON GARY, NY PAUL BURNS, DOVER, DE MARY JOHNSON, MATTITUCK, NY NANCY GARBANI, CALDWELL, ID BLANCA ESTABA, NY ROBB HAUCK, GEORG, IA BARBARA NETT, FOND DU LAC, WI SUSAN MATHEWS, SHEBOYGAN, WI JUDITH WATSON, NY JON ACETO, NY JOHN COCI-IRAN, NY JOIlli R GAGAIN JR DANIEL ABRAMS, NY lliANNE RUSSO, ELIZABETH, NJ ED SCHNABEL, NY MARTIN MORELL, NY KDRISKAT RONDEL LASHLEY, NY THOMAS KLIPPEL, EAGLE RIVER, AK MARTI-IA CAMERON, NEW YORK, NY MICHAEL WARREN, WDM, IA GRETCHEN BARTON, NY HERB HENDERSON, COTTONWOOD, AZ TOMMY GREEN, MOBILE, AL PABLO NARVAEZ, NY MIRKO CLARKE, NY LEE WILLIAMS, NY SARAH POPE, NY DAVID KOELLER, ELIZABETH, NJ PAUL VIRGA, NY NANCY SAUER, AURORA, IL MARSHA RADULOVICH, PORT ORANGE, JANICE FISHER FL JANET GOLDNER, NY CAROLE MONFERDINI, NY MINDY KIM, NY JANET CRUZ, NY JOIlli MOFFETT NICOLA BOTTERO, NY lliFF WOOD, NY ROSALYN LOVECCHIO, LODI, CA AMANDA PORTER-COX, WINSTON-SALEM, NC SUSAN MOODY, PA MIKE KRAMER, NY MARIE HORTON, CEDAR BLUFF, VA DAVID LICHT, NY DELORES AUSTIN, NEW CITY, NY KRISTIN WINKLER, NY CHRISTOPHER DUNCAN, NY CHRISTOPHER WALSH, NY PATRICK FOX, NY EDWARD CAMUFFO, RENO, NY FLORENCE GILCHRIST, NY KEVIN FRICKE, COLUMBUS, OH PETER DEVITT, NY lliFFREY KORN, NY ARTINEH HAVAN, NY MARCIAPATT, SAN DIEGO, CA NADIA W ALLACE, BROOKLYN,
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