Jun. 15, 2022
Secretary Vanessa A. Countryman Countryman, I, being among many retirees as presently employed individuals Investors, have relied on retirement plans like a 401K, pension, or IRA. Much research and everyday news let’s us know we can no longer ignore the reality of climate change & the need for all of us to do our part. Investment managers need access to standardized, comparable information about public companies’ vulnerability to climate change, their current greenhouse gas (GHG) emissions, and their plans to manage climate risks and make good on their public climate commitments. It’s currently challenging for investors and other participants in the market to completely understand the risks / benefits and opportunities with our current environment of permitting companies to voluntarily choose what they want to report, how they want to report, and even whether or not they want to disclose their climate-related financial risks. I stand with many others who support the Securities and Exchange Commission (SEC)’s recent proposal (87 FR 21334; File No: S7-10-22) to require public companies to make standardized, mandatory disclosures about their climate-related financial risks within annual SEC filings. This support encompasses the inclusion of Scope 1 (business operations) and Scope 2 (purchased energy) GHG emissions reporting, in absolute and intensity terms. The SEC is strongly encouraged to strengthen the final rule by requiring Scope 3 GHG emissions (e.g., product and supply chain emissions) disclosure from all large registrants, and to include disclosures around environmental justice, Indigenous rights, a just transition for dislocated workers, and community-level impacts. We currently have a malfunctioning system of inadequate, not comparable, voluntary climate risk disclosure for which this proposal addresses. It will protect investors, encourage prospective retirement savers to invest in the U.S. capital markets, and provide market participants with the climate-related information they need to accurately price climate risk and make well-informed investment decisions. Thank you, Kim Sadlier