Subject: File No.
From: Jesse Hathaway
Affiliation: Policy Advisor, The Heartland Institute

May 28, 2021

These disclosures will negatively impact the market value and performance of affected businesses. Larger funds will be able to exert undue pressure on business owners, effectively reducing their efficiency and increasing the cost of compliance. Big businesses use government edicts to squash smaller competitors all the time, and this proposal is no different.

Additionally, this proposal duplicates existing disclosure rules, needlessly making more paperwork for business owners and ramping up the cost of compliance. Businesses are already required to disclose climate risks to investors, so no new essential information would be gained from this rule.

Finally, the SEC should not usurp the role of Congress to make environmental policy. Congress has ample ability to set federal environmental rules, so its useless and power-hungry for SEC to try to run around Congress constitutional authority and play at making policies in sectors outside its expertise and proper realm.