S7-24-19 Letter Type A

The following Letter Type A, or variations thereof, was submitted by individuals or entities.

Subject: Please vote no on new rule for Section 13(q) of the Securities Exchange Act of 1934

Dear Rule Comments,

I’m writing to you today to urge you to vote no on the proposed rule implementing Section 13(q) of the Securities Exchange Act of 1934, which was added by the Dodd-Frank Wall Street Reform and Consumer Protection Act.

If passed in its current form, this rule would undermine the anti-corruption purposes of the Dodd-Frank Act and allow fossil fuel companies to win a competitive advantage through secretive influence of government officials.

The purpose of this rulemaking is to require resource-extractive companies to comply with transparency requirements and halt corruption within the fossil fuel industry. The latest iteration of the rule, however, would reduce the types of payments to government officials subject to disclosure and only require fossil fuel companies to make public disclosures of reports at a national level instead of on a contract-by-contract level, making it nearly impossible to hold them accountable for corruption.

Further, the rule’s reporting and transparency requirements do not align with existing international standards. By loosening restrictions, the U.S. will become a global laggard on transparency and accountability compared to countries such as those in Europe that have implemented rules modeled after the Dodd-Frank provision.

If the Securities and Exchange Commission is committed to stopping corruption within the fossil fuel industry and using the Dodd-Frank Act as Congress intended, it must vote no on this proposed rule and go back to the drawing board.

Thank you for your time. If you have any questions, please contact the National Whistleblower Center and info@whistleblowers.org.

Thank you for your time,

Sincerely,