November 29, 2007
Nancy M. Morris, Secretary
U.S. Securities and Exchange Commission
100 F St., NE
Washington, DC 20549-1090
Re: File No. 4-547, Request for Interpretive Guidance on Climate Risk Disclosure
Dear Ms. Morris:
I am writing to endorse the “Petition for Interpretive Guidance on Climate Risk Disclosure” filed with the Commission on September 18, 2007.
Our company -- Taplin, Canida & Habacht -- is a registered investment advisor (RIA) with over $8 billion in assets under management in fixed income portfolios managed on behalf of public and corporate pension funds, endowments and foundations, and other institutional investors. Our investment process emphasizes corporate bonds and incorporates a comprehensive assessment of credit risk of registrants in order to evaluate the attractiveness of a particular issuer or issue. Our credit research incorporates an evaluation of business and financial risk, including the impact of climate change on these aforementioned risks.
We believe the implications of climate risk are significant to registrants and investors alike. As part of our ongoing research efforts, business risks presented by a changing global climate are evaluated on a number of levels. Specifically, we evaluate overall business lines and their sensitivity to economic costs associated with climate change. We also evaluate the evolving political environment as it relates to global climate change and the impact on specific investments. Our analysis of the overall impact of global climate change on the financial and business risk of corporate issuers is incorporated into a relative value approach to portfolio management. Accordingly, our ability to fully evaluate investments is contingent upon adequate disclosure of climate risk amongst corporate registrants.
In our view, adequate disclosure should incorporate an evaluation of both physical and legal risks associated with climate change, as well as financial risks and opportunities presented as a result of a changing global climate. We believe such disclosure promotes a more efficient and fair investment environment. We also believe such disclosure is entirely consistent with meeting our fiduciary obligation to our valued clients.
We agree with petitioners that registrants should assess the regulatory, physical and litigation-related risks they face, and disclose their material risks in SEC filings. Commission guidance would be very helpful in providing investors this information.
Thank you for your consideration of this important issue. We hope our comments will be useful to the Commission and Staff in their deliberations.
Sincerely yours,
Corey M. Amon, CFA
Director of Research
Taplin, Canida & Habacht