Subject: File No. 4-637
From: Judith Rudnicki

April 30, 2013

Please, in the interest of transparency and of the public's right to know who is pulling the strings, I urge the Securities and Exchange Commission to issue a rule requiring publicly traded corporations to publicly disclose all their political spending – and to do so this year.

“Dark money” groups that accept contributions from corporations, but are not required to publicly identify their corporate donors, spent millions of dollars during the 2012 elections. It is a scandal that money from publicly traded corporations – which belongs to investors – can be secretly spent to distort our democracy.

The Supreme Court’s ruling in Citizens United v. Federal Election Commission created the loophole that enables this secret spending, but the SEC has the authority to close it. Please consider the authority to close this loophole as your responsibility to do so.

Both shareholders and the public must be fully informed as to how much corporations spend on politics and which candidates are being promoted or attacked. Disclosures should be posted promptly on the SEC’s web site.

The manipulation of public opinion and the obfuscation engendered by this behind-the-scenes spending undermines the public interest and eats away at the fabric of this nation. Transparency will re-engage those of us who feel that there is no point to politics, no hope of integrity at the core, and who see ultimately the collapse of this democracy which even now buckles under the weight of manipulation and secrecy and the corruption of power.

Thank you for considering my comment.

Judith Rudnicki

CA