May. 03, 2022
Dear SEC Employees, The Securities and Exchange Commission's new draft rule for climate risk disclosure is, as currently drafted, only a first step that might help protect investors in general and enable them to play their proper role in our economic system of evaluating the prospects of their investments and potential investments, and to make wise investment decisions, which have a positive effect on the decision-making and conduct of businesses. Decisions regarding climate risk are extremely important, not just to investors themselves, but to the national and global economies and to people in general. Unfortunately, by leaving it up to companies to determine the significance of Scope 3 emissions particularly when the rule can also shield issuers from liability if they provide false or misleading information the proposed rule may allow companies to omit some (or most) of their emissions from disclosures. This would not be fair to individual investors or to the people affected by their decisions, and could even increase the prevalence of greenwashing with negative, unfair, and even disastrous consequences. I realize that there may be active investors and business people who think that these loopholes might have some benefit for them personally, and some people might even try to make the case that full disclosure of business' climate risks could have some negative consequences, but I ask the SEC to respect the rights and abilities of the smaller and less active investors who don't typically make comments to the SEC along with the rights and abilities of members of the general public who have the right to access information about business decisions that may affect their lives in such a significant way. All of us deserve the transparency of full disclosure of information relating to climate risk. Please strengthen the final rule to address these loopholes. Thank you, Sincerely, Kirsten Saxe