Jun. 25, 2026
I appreciate the opportunity to comment on the proposed rescission of the SEC's climate-related disclosure rules. I respectfully oppose the proposed rescission and encourage the Commission to retain a climate-related disclosure framework that provides investors with consistent, comparable, and decision-useful information. Climate-related risks increasingly have the potential to affect the financial performance, operations, supply chains, assets, insurance costs, and long-term resilience of many public companies. Investors rely on transparent and standardized disclosures to evaluate these risks alongside other financially relevant information. Without a consistent reporting framework, disclosures will remain fragmented, making it more difficult for investors to compare companies and assess long-term risk. Standardized disclosure also benefits companies. A single, nationally recognized framework can reduce uncertainty, improve consistency across markets, and lessen the need for companies to respond to numerous differing investor requests or evolving state and international reporting expectations.. While implementation requires effort, greater consistency ultimately promotes more efficient capital markets and better-informed investment decisions. The United States is home to many of the world's largest public companies and capital markets that attract investors from around the globe. Many major economies have already established or are implementing climate-related disclosure requirements. Maintaining a U.S. disclosure framework helps promote comparability across global markets, reduces unnecessary reporting fragmentation for multinational companies, and supports the competitiveness of U.S. capital markets in an increasingly interconnected investment environment. The Commission states that climate disclosures are inconsistent with a materiality-based approach. However, climate-related risks are material for many issuers, and a standardized framework helps ensure that material information is reported consistently rather than omitted or presented in ways that are difficult for investors to evaluate. The United States has also played a significant role in global economic development and cumulative greenhouse gas emissions. As one of the world's leading capital markets, it is well positioned to promote high-quality, transparent disclosure practices that enable investors to better understand financially material climate-related risks and opportunities. Transparent, reliable information is fundamental to efficient markets.. Investors are best served when they have access to comparable information that enables them to assess financial risks and opportunities over both the short and long term. Maintaining an appropriate climate-related disclosure framework supports informed capital allocation, market efficiency, and investor confidence. Thank you for considering these comments.