Seven years ago, Professor Robert Jackson joined 9 other academics in petitioning the SEC to adopt a rule requiring disclosure of political spending.  Professor Jackson is now an SEC Commissioner.  Not surprisingly, Commissioner Jackson supports the SEC's adoption of a political spending disclosure rule.

Recently, Commissioner Jackson co-authored a paper countering arguments against adoption of such a rule.  One of the arguments that he tackles was advanced by this author:

"Opponents of the petition also maintain that public companies will incur substantial reporting expenditures if they are required to disclose political spending to investors. These expenses might include, for example, the internal controls and legal expenses associated with preparing such disclosures. Keith Paul Bishop, the former California commissioner of corporations, advanced this argument in a letter to the SEC opposing the petition, and the Chamber of Commerce has argued that disclosure rules in this area would 'impose substantial costs on public companies' that would outweigh any benefits of disclosure. Even if the marginal burdens imposed by a rule on corporate political spending are minimal, these critics argue, disclosure rules now cumulatively impose substantial burdens on public companies, and the SEC should not add to these burdens by requiring additional disclosure on political spending."

(footnotes omitted).  Given that my letter was among over 1.2 million comment letters submitted to the SEC with respect to the rulemaking petition, I am pleased to see that it was even noticed.