June 11, 2021
Christian Brothers investment Services (CBIS) submits this public comment in support of a rulemaking by the SEC on mandatory climate change disclosures. We believe that disclosure of the material and systemic risks of climate change will help companies and investors to understand, price, and manage climate risks and opportunities. These activities are not only at the core of efficient securities markets, but are also essential to ensuring a just and thriving economy that works for all people and communities.
With over $10 Billion in Assets Under Management, CBIS serves Catholic institutions and religious communities looking to transform the world. We are a member of the Interfaith Center of Corporate Responsibility (ICCR), a 50-year-old coalition of more than 300 faith- and values-based institutional investors who engage with hundreds of corporations on their environmental and social impacts. Together with ICCR, CBIS has been engaging for decades with companies on the risks posed by climate change and therefore deeply understand the value of comparable, consistent, and reliable climate-related information. CBIS believes climate disclosures are critical for effective investment decision-making.
Climate risk disclosure would bring significant benefits to investors and companies. Investor interests in climate-related data include potential impact on financial returns, but also to fulfill governance and stewardship responsibilities as fiduciaries, which necessitate examination of long-term climate-related risks and impacts. This calls for disclosures of climate information across short, medium, and long-term time horizons. Investors current process of engagement on climate disclosures on a company-by-company basis is inefficient and slow, which limits the availability of information to investors and perpetuates the systemic risks of climate change.
Mandatory climate disclosures would improve efficiency, reduce engagement costs, and protect investors from broad climate-related risks across capital markets.
Climate change risks are directly connected to human rights and other environmental issues. As a faith-based investor, we call on the SEC to consider the interconnections between climate change, racial justice, and human rights, as the worst impacts of climate change are often borne by low-income communities and communities of color. These disproportionate impacts contribute to social inequities, which can have negative consequences on the economy and the environment. We encourage the SEC to explore the integral connection between climate, water, food and forests.
The climate crisis requires immediate action to mitigate the growing threats to financial markets and the economy, as well as to the people and communities that exist within them therefore, we ask the SEC to act urgently in its climate disclosure rulemaking process.
We appreciate the opportunity to participate in the SECs request for information and thank you for your consideration of our comments.