Subject: Comment on S7-10-22
From: Cheryl Arney
Affiliation:

Sep. 16, 2022


Dear Chair Gensler, I am writing to thank you for taking steps to make it easier for investors like me to understand climate risk. As an investor looking to maximize my returns, I need to know whether or not a company is preparing to be successful in a low-carbon world. More and more economies are adopting policies and taking steps to align with the goals of the Paris Agreement. Companies not working to reduce their Scope 1, 2 and 3 greenhouse gas emissions may not be prepared for that future. Without this information, I won't be able to tell what companies are likely to continue to be profitable as the economy transitions to clean energy and which companies could put my savings at risk. Earlier this summer you proposed a rule to require publicly traded companies to disclose "material" Scope 3 emissions. Many investors - both asset managers and individual investors like me - asked you to make this a requirement for all large public companies, and I am hopeful that you will listen to the voices of regular people like me, not just big corporations looking to hide their risks. As you look to finalize these rules, I wanted to thank you for doing everything in your power to ensure that investors like me have the information we need to be able to make smart investing decisions for a low-carbon future. I am looking forward to seeing strong greenhouse gas disclosures, inclusive of Scope 3 emissions, in your final ruling later this year. 

I personally invest in an ESG mutual fund. But how can I know if I've made a "good choice" in the ESG fund I've chosen if there's no transparency on greenhouse gas emissions? The reason I've chosen to invest in an ESG fund is because I care deeply about transitioning not only the U.S. economy but the world to zero greenhouse gas emissions. I believe climate change is an existential threat to life on this planet. Arguably we are currently witnessing the 6th great extinction. Climate change is a "big deal". But I can't make wise choices if I can't get accurate information. That's why the SEC's decision in this matter is so important. Small investors like me need all the help we can get from the SEC in making investment decisions that align with our values and morals. Please take us into account when making this decision.