March 25, 2022
I am writing as a private investor and I oppose adoption of the proposed disclosure requirements. Others can argue better whether this topic, however noble, is within the SEC's legal purview. My objection is that this requirement will impose significant costs and burdens on issuers while providing little to no value to investors.
The disclosure requirements proposed will be a major distraction from issuers' core business and inflict significant compliance burdens that never go away. Resources that could be used to grow the business or enhance compliance efforts will be diverted to pay consultants to compile the necessary data.
While there are investors that are guided by ESG concerns, that is their choice and there are already many resources to help them find companies with the profile they desire. It is wasteful to inflict this requirement and its attendant cost on all issuers, most of whom are not in GHG-intensive businesses, and investors, most of whom are more concerned with making sound investment decisions.
It would be a mistake to implement this proposed disclosure requirement. however well-intentioned it might be.