Currently, shareholders have a right to make proposals in the company s proxy statement to provide disclosure of charitable contributions. Those proposals have not attracted substantial support from shareholders. The Business Roundtable has commented that few shareholders request information regarding charitable contributions from companies that provide this information voluntarily. This leads us to believe that a significant majority of shareholders may not consider this information to be important. In recent years, the Commission has been focusing much of its efforts on streamlining disclosure and mandating plain English.
Charitable contributions account for a small portion of most companies financial activities.
We are cautious about adding disclosure that would add to the volume of detail given to investors without providing material information. In the course of reviewing H. R. 887, the Commission staff identified additional practical issues that may affect the implementation of disclosure requirements for corporate charitable giving. Although companies already track the amount of their charitable contributions and to whom they are made for tax purposes, they may not have in place mechanisms to identify gifts to organizations affiliated with corporate insiders and their spouses, in part because they are not currently required to do so. Also, depending upon the dollar thresholds for disclosure, the amount of disclosure and the corresponding cost burden will vary significantly. Finally, there are other technical issues that the staff would be pleased to discuss.