May 14, 2008
Dear Ms. Morris:
I write in full support of the “Petition for Interpretive Guidance on Climate Risk Disclosure” filed with the Commission on September 18, 2007.
As an employee of Newground Social Investment, an investment firm focused solely on ESG (Environment, Social, and Governance) factors, and as an individual investor concerned about the risks of climate change, we require complete disclosure on the part of corporations in order to make informed decisions about the suitability of investments.
The failure of companies to uniformly and fully disclose their climate change risk poses a direct and negative risk, not only to our client portfolios, but to the companies themselves.
Since the SEC is responsible for ensuring a level playing field, such that the corporations and investors alike can count on the same set of rules applying to everyone, full disclosure of material risk climate change poses needs to be mandated.
Already, SEC -registered corporations are required to assess the regulatory, physical and litigation-related risks they face from a host of other factors. As we learn more about climate change from scientists, it makes perfect sense to add this to the considerations all corporations must now disclose.
I hope the Commission and Staff have found my comments useful in its careful deliberations, and I look forward to a forward-thinking ruling.
Sincerely, Nancy Herbert Seattle, WA