April 24, 2022
Ms. Vanessa A. Countryman
Secretary
U.S. Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549-1090
RE: File Number S7-10-22
The Enhancement and Standardization of Climate-Related Disclosures for Investors
Dear Ms. Countryman:
I am writing you today in reference to SECs proposed rule requiring domestic or foreign registrants to include certain climate-related information in its registration statements and periodic reports.
I for one, am in favor of requiring these registrants to disclose this information. It allows for the public another metric with which to decide between companies when investing. For me personally, I would absolutely use this metric in my investing decisions. Would it be the only metric I look at? Absolutely not. At the end of the day it is a financial decision that I depend on. However, if I am stuck between two companies that I want to invest in, I would look at the climate data and it could potentially sway me one way or the other. For example, if I am wanting to invest $10,000 into either Apple or Microsoft I might go with Microsoft if their carbon footprint is significantly lower. Personally, I feel the greater chance for a better return lies with Apple, but if Apple turns out to be the worlds biggest GHG emitter I would choose Microsoft.
One issue I did want to discuss, was the verification and validation of these reports. I strongly support the SEC to require third-party consultants audit this climate data to ensure its validity. I believe it should almost be a standardized form that registrants must provide that discloses the climate data in a set series of metrics so that investors can compare one companys data to another without getting lost in trying to understand the data. I think these third-party consultants should be engineering and environmental firms that employ qualified environmental consultants who can independently verify the statements the company is making.
Thank you very much,
Ryan Millunzi