Jun. 11, 2021
To whom it may concern: Here is my input on the Climate Change Disclosures. The SEC should develop a comprehensive framework to help ensure that companies report more consistent, complete and comparable information relevant to their long-term risks, opportunities and performance. Voluntary reporting leads to significant data gaps, especially among medium and small companies. ESG disclosure must be mandatory for all reporting issuers in the United States. ESG disclosure must have comprehensive information to allow investors to gain a holistic understanding of company practices. ESG Disclosures should allow comparisons among organizations within sectors, regions, industries or portfolios. Harmonize, where possible, with existing international standards to prevent comparability mismatches that leave the information generated less useful for investors framework should be designed to evolve in a timely manner as new issues emerge. Other considerations for the SEC Climate risk is not currently priced by financial markets because people don’t have the information they need to assess physical risk. Human capital disclosures should at minimum require EEO-1 reports, pay gap ratios for all demographics, employee turnover and composition of the workforce. All the best, Stephanie Cohn Rupp | CEO and Partner She/Her