March 24, 2022
I am writing to support the proposed SEC rule regarding climate related disclosures.
America has fallen behind other financial jurisdictions in regards to climate disclosures. Jurisdictions like the U.K., E.U., Hong Kong, Singapore and New Zealand have already announced rules regarding climate disclosure. While the world's best companies have the ability to be listed in many different countries, they often choose America in no small part due to our strong regulatory and accounting oversight. Maintaining this positioning is crucial if we are to continue to dominate the global financial ecosystem. I believe that this proposed rule will help America remain at the forefront of global markets.
Some of the criticism against this rule is valid, however we cannot allow perfect to be the enemy of good. Enacting a rule to measure carbon emissions is a critical first step in addressing climate change. Furthermore, the provision of a safe harbor for liability from Scope 3 emissions disclosures made in good faith protects the reporting companies from a major risk. This example demonstrates that the rule is crafted to be well balanced between the interests of investors and public corporations.