May. 08, 2022
Hello, Thank you for the opportunity to comment on file #S7-10-22, requiring registrants to provide certain climate-related information in their registration statements and annual reports. I believe this requirement to be an onerous task that would be too complex to manage, costing businesses time and accuracy which will result in an incentive to no longer continue in business instead of an incentive to maintain business operations. The effort to compile these metrics will be complicated and not consistent across businesses. Each participating business will is likely to have to hire additional staff to collect and submit these metrics. This is fine for a large business but could be a deterrent for a small business. Reference the effort and time that the FDA has taken to develop the program for Quality Metrics. This has been underway for 5+ years and is not yet useful and returning value. The FDA continues working with businesses to develop a value-adding process and system. This is appreciated by both businesses and FDA. A similar evaluation process is needed for the climate-related metrics program to ensure consistency and value to the SEC, the participating business and with the customer, who is ultimately going to pay an increased price for the products or services that the business provides. It is well known that added regulations that government applies to businesses result in higher prices to customers due to the added complexity. This should be taken into consideration prior to the change in requirements. Thank you, Jennifer Cocklin