Jun. 21, 2022
June 16, 2022
Credit Roundtable Members and interested parties
European Leveraged Finance Association
Sabrina Fox
Fixed Income Forum
Lisa Yao
Canadian Bond Investors Association
Peter Waite
SEC Office of Investor Advocate
Adam Anicich
Adam Moore
CreditSights
Winifred Cisar
FICC Market Standards Board
Investment Association
International Organization of Securities Commissions
Covenant Review
Alexander Diaz-Matos
SIFMA
Joseph Corcoran
FINRA
Ola Persson
Standard and Poor’s
Moody’s
Fitch
KBRA
VIA ELECTRONIC FILING
Secretary Vanessa A. Countryman
Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549-1090
Re: File Number S7-10-22: The Enhancement and Standardization of Climate-Related Disclosures for Investors
Dear Secretary Countryman,
The Credit Roundtable would like to express our gratitude to the Securities and Exchange Commission (“Commission”) for the opportunity to comment on the proposed rules seeking to standardize and make enhancements to climate-related disclosures.
We are a group of large institutional fixed income managers including investment advisors, insurance companies, pension funds, and mutual fund firms, responsible for investing more than $4 trillion of assets. The Credit Roundtable (“CRT”) advocates for creditor rights through education and outreach and works to improve fixed income corporate actions, ineffective covenants, and the underwriting and distribution of corporate debt. Its mission is to improve risk assessment and management through education with the goal of benefitting all bond market participants through increasing transparency, market efficiency, and liquidity. Our membership includes firms that employ analysts who specialize in assessing the impact of Environmental, Social and Governance (“ESG”) issues on corporate debt issuers. The comments which follow represent common threads across our membership and may at times align and at times diverge from the feedback the Commission may receive from equity-focused organizations and investors.
In our 2021 comment letter to the Commission[1], we provided feedback and views regarding the implementation pace of ESG disclosures and standards as they relate to Green and Sustainable-Linked bonds. The guiding principle is effective, consistent, and standardized disclosures of material pre-financial ESG factors.
Our membership generally believes that the information required by the Proposed Rules is necessary for a robust assessment of risks, and thereby, to support fair, orderly, and efficient markets and to promote capital formation. Furthermore, we consider the Proposed Rules a significant step forward towards harmonizing disclosure practices
The CRT supports the Commission’s Proposed Rules, as we believe material climate related disclosures are useful to investors seeking to understand the risks and opportunities presented by climate change. Existing disclosures are largely principles-based and are highly bespoke. This has led to low quality, incomplete and inconsistent data in a variety of qualitative and quantitative formats, making it difficult for investors to understand and price.
We thank the Commission for its consideration of these comments and welcome the opportunity to discuss our concerns, opinions and recommendations in greater detail. Please direct any questions to Kelly Byrne Skarupa of The Credit Roundtable at kbyrne@taminc.com or (914) 332- 0042.
Sincerely,
The Credit Roundtable
25 North Broadway
Tarrytown, NY 10591
Phone: 914-332-0042
Email: kbyrne@taminc.com
Website: www.thecreditroundtable.org
LinkedIn: The Credit Roundtable
Cc: The Honorable Gary Gensler, Chair
The Honorable Caroline A. Crenshaw, Commissioner
The Honorable Allison Herren Lee, Commissioner
The Honorable Hester M. Peirce, Commissioner
Securities and Exchange Commission
[1]https://cdn.ymaws.com/thecreditroundtable.org/resource/resmgr/recent_news/210611crtcommentlettertoseco.pdf
[1]https://cdn.ymaws.com/thecreditroundtable.org/resource/resmgr/recent_news/210611crtcommentlettertoseco.pdf