Jun. 01, 2021
Tuesday, June 1, 2021 Dear SEC Commissioners: We as investors, corporations, non-profit organizations and individuals, support climate change disclosure rulemaking by the Securities and Exchange Commission. We believe that disclosure of the material and systemic risks of climate change will help companies and investors to understand, price, and manage climate risks and opportunities. These activities are at the core of efficient securities’ markets and are essential to ensuring a just and thriving economy that works for all people and communities. Climate change poses a systemic risk to the economy. The impacts of the climate crisis on our lives and our livelihoods are worsening at a dramatic rate. These include physical risks to real assets from climate-fueled weather events and transition risks posed by regulatory, technology, economic and litigation changes during the shift to a net-zero economy. We also call on the SEC to take into consideration the broader impacts of climate change as a part of the rulemaking process, including the physical and transition impacts of the climate crisis on communities, human rights implications and the connection between climate, water, food and forests. We appreciate the SEC's Request for Information on climate change as it allows for comprehensive input about the issues the SEC must resolve to meet the needs of all market participants. We believe that climate change disclosure rules from the SEC should, at minimum, include the following elements: • Based on the Task Force on Climate-related Financial Disclosures (TCFD) which has been endorsed by hundreds of companies and investors globally. • Industry specific metrics: SEC rulemaking should include industry specific metrics, because material climate risks manifest in different ways by industry. Identifying such industry specific metrics would also allow for comparable disclosures. • Governance and strategy disclosure: Disclosure rules should provide insights into companies’ climate risk exposure, strategies and scenario planning. • Emissions disclosure: Disclosure rules should include Scope 1, 2 and 3 greenhouse gas emissions, which are needed to assess the full range of climate change risks facing companies. • Inclusion in financial filings: Material climate disclosures, including discussion on risk exposure and business opportunities, impacts on strategy and emissions reporting and management, should be included in all appropriate SEC filings. • Regular updates: Climate change impacts, scientific consensus around climate impacts and capital market responses to climate risks are rapidly evolving. SEC rules should be updated regularly in response to these developments, and they should include the development or adoption of new metrics. We sincerely appreciate the Commission’s consideration of our views, and we look forward to working with you. We urge the SEC to act urgently in response to the growing threats of the climate crisis to markets and the economy. Sincerely, Katherine DiMatteo