Subject: File No. S7-10-22 [CMCK-UK.FID13756145]
From: Tim Malloch

Jun. 15, 2022

File No. S7-10-22
The Enhancement and Standardization of Climate-Related Disclosures for Investors
Consultation response
Dear Securities and Exchange Commission,
I refer to the above consultation on the proposed rules for climate-related standard disclosures for investors and attach two articles in PDF format.
The articles argue that recent developments in climate-related financial disclosure obligations in the US, the UK, and the EU suggest that the most logical progression of these developments is that central banks move from their current positions as observers and intervene to introduce a carbon coin, a digital currency disbursed on proof of carbon sequestration or the provision of climate stewardship services.
(i)          the PDF document titled “COP 26, carbon coins, and cockroaches-Can a new form of currency mitigate corporate liability climate risks” explains that financial reporting obligations are likely to become a key feature of corporate liability in relation to climate-risks and that the information disclosed as a result of these new processes is likely to confirm and compound existing concerns that the UN COP process, in its current form, is inadequate.
(ii)         the PDF document titled “The carbon coin and climate-related financial disclosures” discusses two of the issues that may fall to be disclosed under the SEC proposed rule on climate-related disclosures for investors: (i) a registrant's use of carbon offsets; and (ii) whether it has set an internal carbon price.
In short, companies and investors that prepare climate-related financial disclosures may appreciate that their best efforts in isolation are unlikely to be sufficient and that more needs to be done. The disclosure process may therefore encourage companies to persuade central banks to intervene with monetary policies that help achieve national climate targets, such as sustainability bonds and the carbon coin, to create a positive global price for carbon.
Tim Malloch
Tim Malloch 
Senior Associate

(Attached File #1:s71022-20131325-301507.pdf)(Attached File #2:s71022-20131324-301507.pdf)