March 27, 2022
I am concerned about this rule only because it allows companies to effectively determine for themselves whether Scope 3 emissions are \"material\" or not. This seems more like a continuation of the failed neoliberal \"self-regulation\" model the SEC has traditionally operated under (partly due to the revolving door between SEC staff and the companies it is supposed to regulate).
However, I strongly commend the remainder of the rule, which is long overdue. With climate change poised to take an ever greater toll on property around the world, the economic impacts will be felt by all via the stock market, and investors should be able to easily know which companies have the greatest climate risks so that a truly free market (with minimized information asymmetry) can take hold. Every game needs a referee to be truly fair, and the SEC needs to start calling more fouls when it sees them.