Subject: File No. S7-06-16
From: Jay Siegel
Affiliation: Real Estate Consultant, JLL

July 21, 2016

The need for sustainability reporting around Environmental, Social, and Governance (ESG) structures has never been more important. Investors deserve a material and transparent way to compare the sustainability attributes of companies.A one size fits all solution for reporting sustainability performance wont work. Standardizing sustainability disclosure will improve the material information that investors can use to make decisions, but every industry is different. For example, a real estate company may find its risk around climate change because rising sea levels devalue its coastal assets but an airlines highest risk might be around volatility in fuel prices or technology costs from shifting to a new propulsion system. Sustainability disclosure will be complicated but worth the effort for investors to understand an apples to apples comparison of performance.