Jun. 10, 2021
I am writing to inform you of my opinion of the following: • 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 Patricia Addeo, Senior Associate, Wealth Management She/Her