From: Darren Walker
Sent: July 1, 2016
To: rule-comments@sec.gov
Subject: File No. S7-06-16, Business and Financial Disclosure Required by Regulation S-K

Brent Fields, Secretary
Securities and Exchange Commission
100 F Street NE
Washington, DC

RE: File No. S7-06-16, Business and Financial Disclosure Required by Regulation S-K

Dear Mr. Fields,

On behalf of the U.S. Alliance for Impact Investing (formerly known as the U.S National Advisory Board), we are writing in support of improved disclosure standards related to sustainability and materiality. We see the Reg S-K (S7-06-16) as a vital tool to increase the flow of investment capital for public good which now, more than ever, is needed given the pressing social and environmental challenges our planet and country faces. While recognizing that the number of investors and companies engaged in Environmental, Social and Governance practices has grown significantly, we also know, through evidence, that current measurement and disclosure efforts are uneven at best. This unevenness has created skepticism among investors and companies which has limited even more significant flows of capital from creating powerful new opportunities for positive impact.

As a movement of committed impact investors representing asset owners and managers (foundations, investors, and entrepreneurs alike) with a focus on positive social and environmental impact, we ask that the Securities and Exchange Commission consider requiring standard sustainability and materiality reporting. The Sustainability Accounting and Standards Board (SASB) offers one such platform to utilize a robust and comprehensive set of standards backed by years of effort and supported by a range of key stakeholders.  The number of stakeholders that stand in support of SASB is a testament both to the sense of urgency in needing these standards as well as the diverse range of interested parties.

The Securities and Exchange Commission has the opportunity to transform how finance benefits society. We welcome its leadership in this important endeavor.

Respectfully,
 
Darren Walker, Chair
President, Ford Foundation
Matt Bannick, Co-Chair
Managing Partner, Omidyar Network
Tracy Palandjian, Co-Chair
Chief Executive Officer & Co-Founder, Social Finance