April 11, 2022
The proposed SEC rules changes to 17 CFR 210, 229, 232, 239, and 249 (File No. S7-10-22 S7-10-22, RIN 3235-AM87, The Enhancement and Standardization of Climate-Related Disclosures for Investors) is out for public review.
One of the key proposals is The Greenhouse Gas Protocol. This portion of the proposed rule change states Quantitative greenhouse gas (GHG) emissions data can enable investors to assess a registrants exposure to climate-related risks...This data also could help investors to assess the progress of registrants with public commitments to reduce GHG emissions, which would be important in assessing potential future capital outlays that might be required to meet such commitments.
Personally have many concerns with this entire proposed rule change, the main ones being:
1) The change is NOT based on proven science regarding GHG's or any other proven impact, merely a UNIPCC political science hypothesis based on correlation conjecture, circular logic and supporting models,
2) The change places additional meritless government burdens on industry and related investors, and
3) The change originates from recommendations made by self-appointed, self-interested parties (e.g. FSB, TCFD, etc.) NOT representing the best interests of the American people.