April 6, 2022
We understand that the SEC has a large sophisticated staff who put an enormous amount of time into this climate disclosure proposal. The proposal, with more than 1,000 footnotes, cites abundant sources from equally sophisticated researchers and institutions. We also understand that the hearts of these participants are probably in the right place.
But the law does require the proposal to evaluate the costs and benefits to investors, and the SEC has long been the champion of the individual investor, the ordinary American. Yet the retail investor is mentioned only once in the 500+-page document.
We ask the SEC in its next draft of this proposal to include an extensive section addressing the costs and benefits to the everyday individual investor, reflecting the diversity of views on this complex topic and acknowledging that not all Americans will agree with the views or conclusions of the SECs sophisticated staffers and large powerful institutional investors and asset managers.