Subject: File No. Disclosure Effectiveness
From: Samuel C Adams
Affiliation: Vert Asset Management

July 15, 2016

We would like to join the chorus of requests for the SEC to require disclosure of material risks related to environmental, social, and governance factors. In particular, we believe it's time for US companies to report their Greenhouse Gas Emissions (CO2 equivalent) as part of their standard disclosures. The amount of energy a company consumes is a material factor in understanding the firms' costs and risks. Furthermore, the sources of the energy consumed is important to know, as it directly impacts the carbon footprint. We do not believe these disclosures would be onerous or costly to provide. What's clear is that this information would help investors a great deal.

Thank you,

Sam Adams
Vert Asset Management