April 24, 2022
What I found most interesting about this proposed rule, was the section from page 120-129 that specifies on the idea to require businesses in areas negatively affected by climate-related reasons. As far as I can understand, all variables were accounted for in this proposal, and it would be extremely helpful for the general public to receive full disclosure about how catastrophes such as hurricanes or earthquakes have affected their places of employment, not to mention the local economy as a whole. Of course, it is also a major help for stockholders in said businesses, so that the corporations theyve invested in cannot hide their losses until the next mandatory quarterly report, which (by then the chance to sell said stock, and still flip a profit) is far too late.
From pages 389 to 392, there is a section elaborating on how the aforementioned mandatory climate disclosures would have their information disseminated to the general public. While the major points come across well to a reader, I find that it would be far more helpful if more elaboration was made into detailing the steps of the process of how exactly this information is given to third-party services, and how said third-party services release this information to the general public. And shouldnt this sort of information be released under the jurisdiction of the Freedom Of Information Acts office? I do completely agree however, on how the demand for this information will help the economy of scale in the long-run, as do the majority of high-demand services with low overhead incurred costs.
One last issue I would be interested in seeing clarification on: in page 52, a good elaboration is made on how previous commenters wanted the Securities Exchange Commission to have a rubric for quantitative climate data reports that emphasize the climate data metrics over profit spreadsheets and other similar paperwork. In a further revision of this proposed rule, it seems prudent to have a template or a fictional example on how a report should be made, assuming this rubric request is heeded at all.