May. 17, 2022
Dear Commissioner Gary Gensler, I just wrote to the SEC with concerns about their proposed climate disclosure rule, File Number S7-10-22. The SEC is rushing to jam through a rule that raises huge issues, and I have shared these concerns with the SEC. The SEC proposed rule is 510 pages long, with 1,068 technical footnotes and 750 direct questions. Unlike corporations currently regulated by the SEC, farmers and ranchers, don’t have a team of compliance officers or attorneys dedicated to handling SEC compliance issues. There are many questions about how privacy will be protected, what the substantial costs and legal liabilities will be, and whether reporting requirements will disqualify small, family-owned farms from doing business with public companies, or companies that supply public companies, which would have the unfortunate effect of causing more consolidation in agriculture. This is an example of overreach by the Securities and Exchange Commission. What are you going to do to stop the SEC? Regards, Gary Joiner