October 22, 2019
To All Concerned,
I am writing in support of the comment letter you have received, on this subject, from the Sustainability Accounting Standards Board's (SASB,) Thomas L Riesenberg, their Director of Legal and Regulatory Policy dated October 17, 2019.
In particular I support the use of line item requirement with comparable metrics, instead of free-form self-selected disclosures, potentially using boilerplate language. The most important points, in my view, made in SASB's October 17th letter begins towards the bottom of its page 11, where it says,
"First, broad corporate use of the standards should limit executives discretion in what to disclose. This is because SASB's guidelines provide that a company using the SASB framework should use all the metrics applicable to that company's industry or, alternatively, to explain why it is omitting certain metrics. This approach ensures that companies will disclose comparable information and enables investors to benchmark performance across companies.
Second, concern about inconsistent information that investors cannot easily compare is at the heart of the SASB initiative. Inconsistency and lack of comparability draw to a close when companies use an established industry-specific disclosure framework."
My thanks to the Commission and its staff for the time and consideration given to my comments.
Sincerely,