April 11, 2022
Dear SEC,
The proposed draft rule for climate risk disclosure is an important first step in protecting investors and consumers to have clear, consistent and reliable information about companies greenhouse gas emissions and their plans to protect the environment in deciding whether to support them either through investment or purchase of the goods and services they provide. Its a great start to hold companies be accountable and to be more transparent about their greenhouse emissions and will allow millions of individuals to make informed investment and/ or purchase decisions. But the proposed rule doesn't go far enough. By leaving it up to companies to determine the significance of Scope 3 emissions particularly when the rule can also shield issuers from liability if they provide false or misleading information the proposed rule may allow companies to omit some (or most) of their material emissions from disclosures.
Kindly strengthen the final rule to address these loopholes and protect our planet and the financial system from climate-induced risk by passing a strong, science-based climate disclosure rule as soon as possible.
Sincerely,
Priyanka Mandal