Comments on: Toward SEC Rules on Disclosure of Political Spending http://blogs.law.harvard.edu/corpgov/2011/08/04/toward-sec-rules-on-disclosure-of-political-spending/ A law and economics blog from the Harvard Law School Program on Corporate Governance that gathers the latest news, opinion and research pertaining to corporate governance and financial regulation. Thu, 23 May 2013 11:00:25 +0000 hourly 1 http://wordpress.org/?v=3.4.1 By: Support Rulemaking Petition on Corporate Political Spending | Corporate Governance http://blogs.law.harvard.edu/corpgov/2011/08/04/toward-sec-rules-on-disclosure-of-political-spending/comment-page-1/#comment-1559745 Support Rulemaking Petition on Corporate Political Spending | Corporate Governance Sun, 11 Nov 2012 03:42:45 +0000 http://blogs.law.harvard.edu/corpgov/?p=20168#comment-1559745 [...] petition was submitted by the Committee on Disclosure of Corporate Political Spending, co-chaired by Lucian A. Bebchuk, Professor of Law, Economics, and Finance at Harvard Law School [...] [...] petition was submitted by the Committee on Disclosure of Corporate Political Spending, co-chaired by Lucian A. Bebchuk, Professor of Law, Economics, and Finance at Harvard Law School [...]

]]> By: Investors Interested in Company Political Contributions | First Affirmative Leadership Blog http://blogs.law.harvard.edu/corpgov/2011/08/04/toward-sec-rules-on-disclosure-of-political-spending/comment-page-1/#comment-1372769 Investors Interested in Company Political Contributions | First Affirmative Leadership Blog Tue, 29 May 2012 07:06:59 +0000 http://blogs.law.harvard.edu/corpgov/?p=20168#comment-1372769 [...] for Sustainable and Responsible Investing to the Securities and Exchange Commission in support of a rulemaking petition that asks the SEC to mandate political spending disclosure for all public [...] [...] for Sustainable and Responsible Investing to the Securities and Exchange Commission in support of a rulemaking petition that asks the SEC to mandate political spending disclosure for all public [...]

]]> By: America Tells the Securities Exchange Commission to Mandate Disclosure of Corporate Political Activity - Harrington Investments http://blogs.law.harvard.edu/corpgov/2011/08/04/toward-sec-rules-on-disclosure-of-political-spending/comment-page-1/#comment-1340993 America Tells the Securities Exchange Commission to Mandate Disclosure of Corporate Political Activity - Harrington Investments Wed, 02 May 2012 17:06:39 +0000 http://blogs.law.harvard.edu/corpgov/?p=20168#comment-1340993 [...] Corporate Reform Coalition was formed after several prominent law professors, filed a petitionurging the SEC to require publicly traded companies to disclose their political spending. [...] [...] Corporate Reform Coalition was formed after several prominent law professors, filed a petitionurging the SEC to require publicly traded companies to disclose their political spending. [...]

]]> By: Jack Ucciferri: America Tells the Securities Exchange Commission to Mandate Disclosure of Corporate Political Activity - DigaNews | DigaNews http://blogs.law.harvard.edu/corpgov/2011/08/04/toward-sec-rules-on-disclosure-of-political-spending/comment-page-1/#comment-1340714 Jack Ucciferri: America Tells the Securities Exchange Commission to Mandate Disclosure of Corporate Political Activity - DigaNews | DigaNews Wed, 02 May 2012 08:46:47 +0000 http://blogs.law.harvard.edu/corpgov/?p=20168#comment-1340714 [...] Corporate Reform Coalition was formed after several prominent law professors, filed a petition urging the SEC to require publicly traded companies to disclose their political spending. In [...] [...] Corporate Reform Coalition was formed after several prominent law professors, filed a petition urging the SEC to require publicly traded companies to disclose their political spending. In [...]

]]> By: Jack Ucciferri: America Tells the Securities Exchange Commission to Mandate Disclosure of Corporate Political Activity - Political News http://blogs.law.harvard.edu/corpgov/2011/08/04/toward-sec-rules-on-disclosure-of-political-spending/comment-page-1/#comment-1340629 Jack Ucciferri: America Tells the Securities Exchange Commission to Mandate Disclosure of Corporate Political Activity - Political News Wed, 02 May 2012 05:37:12 +0000 http://blogs.law.harvard.edu/corpgov/?p=20168#comment-1340629 [...] Corporate Reform Coalition was formed after several prominent law professors, filed a petition urging the SEC to require publicly traded companies to disclose their political spending. In [...] [...] Corporate Reform Coalition was formed after several prominent law professors, filed a petition urging the SEC to require publicly traded companies to disclose their political spending. In [...]

]]> By: Jack Ucciferri: America Tells the Securities Exchange Commission to Mandate Disclosure of Corporate Political Activity - Goldstar News | Goldstar News http://blogs.law.harvard.edu/corpgov/2011/08/04/toward-sec-rules-on-disclosure-of-political-spending/comment-page-1/#comment-1340351 Jack Ucciferri: America Tells the Securities Exchange Commission to Mandate Disclosure of Corporate Political Activity - Goldstar News | Goldstar News Wed, 02 May 2012 02:16:13 +0000 http://blogs.law.harvard.edu/corpgov/?p=20168#comment-1340351 [...] Corporate Reform Coalition was formed after several prominent law professors, filed a petition urging the SEC to require publicly traded companies to disclose their political spending. In [...] [...] Corporate Reform Coalition was formed after several prominent law professors, filed a petition urging the SEC to require publicly traded companies to disclose their political spending. In [...]

]]> By: Jack Ucciferri: America Tells the Securities Exchange Commission to Mandate Disclosure of Corporate Political Activity | USA Press http://blogs.law.harvard.edu/corpgov/2011/08/04/toward-sec-rules-on-disclosure-of-political-spending/comment-page-1/#comment-1340335 Jack Ucciferri: America Tells the Securities Exchange Commission to Mandate Disclosure of Corporate Political Activity | USA Press Wed, 02 May 2012 01:55:29 +0000 http://blogs.law.harvard.edu/corpgov/?p=20168#comment-1340335 [...] Corporate Reform Coalition was formed after several prominent law professors, filed a petition urging the SEC to require publicly traded companies to disclose their political spending. In [...] [...] Corporate Reform Coalition was formed after several prominent law professors, filed a petition urging the SEC to require publicly traded companies to disclose their political spending. In [...]

]]> By: Edward http://blogs.law.harvard.edu/corpgov/2011/08/04/toward-sec-rules-on-disclosure-of-political-spending/comment-page-1/#comment-1250721 Edward Tue, 28 Feb 2012 21:40:05 +0000 http://blogs.law.harvard.edu/corpgov/?p=20168#comment-1250721 What do "we the people" do? What do “we the people” do?

]]> By: Laurie Bennett http://blogs.law.harvard.edu/corpgov/2011/08/04/toward-sec-rules-on-disclosure-of-political-spending/comment-page-1/#comment-1125690 Laurie Bennett Sun, 18 Dec 2011 15:05:00 +0000 http://blogs.law.harvard.edu/corpgov/?p=20168#comment-1125690 You should be interested in this post, about the political activities of Devon Energy Corporation: http://news.muckety.com/2011/12/18/sec-needs-to-require-reporting-of-political-activities/35581 You should be interested in this post, about the political activities of Devon Energy Corporation:

http://news.muckety.com/2011/12/18/sec-needs-to-require-reporting-of-political-activities/35581

]]> By: Keith Paul Bishop http://blogs.law.harvard.edu/corpgov/2011/08/04/toward-sec-rules-on-disclosure-of-political-spending/comment-page-1/#comment-885513 Keith Paul Bishop Mon, 08 Aug 2011 16:23:45 +0000 http://blogs.law.harvard.edu/corpgov/?p=20168#comment-885513 I disagree with the petition for the following reasons: •The burden on reporting companies is already significant and adoption of the proposal will add to those burdens. One day, the camel’s back will be broken by the weight of the incremental burdens placed upon it. •The petitioners make the case that there is an increasing interest in political spending disclosures. They point out that on average these proposals enjoyed 32.5% support during the most recent proxy season. This means that 2/3 of the shareholders do not support political spending disclosures. In fact, the petitioners don’t provide evidence of a single proposal that garnered majority support. •The proposal would be tantamount to a forced subsidy by the majority of the minority. The petitioners do not explain why it is fair or equitable to require the majority to financially support the interest, however legitimate, of the minority in such disclosures. •The petitioners fail to make the case for the need for Commission action. Some of the petitioners’ arguments actually make the case that no intervention is needed. For example, they point out that an increasing number of companies have voluntarily elected to disclose political spending. The fact that so many proposals have been presented tells me that there is no problem in getting them before the shareholders. Why not simply let private ordering occur? I disagree with the petition for the following reasons:
•The burden on reporting companies is already significant and adoption of the proposal will add to those burdens. One day, the camel’s back will be broken by the weight of the incremental burdens placed upon it.
•The petitioners make the case that there is an increasing interest in political spending disclosures. They point out that on average these proposals enjoyed 32.5% support during the most recent proxy season. This means that 2/3 of the shareholders do not support political spending disclosures. In fact, the petitioners don’t provide evidence of a single proposal that garnered majority support.
•The proposal would be tantamount to a forced subsidy by the majority of the minority. The petitioners do not explain why it is fair or equitable to require the majority to financially support the interest, however legitimate, of the minority in such disclosures.
•The petitioners fail to make the case for the need for Commission action. Some of the petitioners’ arguments actually make the case that no intervention is needed. For example, they point out that an increasing number of companies have voluntarily elected to disclose political spending. The fact that so many proposals have been presented tells me that there is no problem in getting them before the shareholders. Why not simply let private ordering occur?

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