April 24, 2022
This proposed rule reflects the importance of disclosing both climate impacts of business and climate risks to business. Both these are priorities for investors to understand when determining where to put their money. However, I think this rule needs more information on suggestions and/or standards for calculations such as internal carbon prices. Additionally, examples for types of climate-related risks/impacts that should be included in the disclosures would be beneficial for compliance. I do believe the SEC needs to do further research on the impacts for small businesses of this rule, although Im not sure it falls under the major rule provision of SBREFA.