April 23, 2022
Disclosure is key for investors to understand the scope and breadth of climate-related risks and their actual or likely material impacts facing public companies when making decisions. Per the proposal, investors are currently seeking this kind of information in order to identify the risks that a business may face in terms of how they currently operate, their current plan around mitigating climate change, and how any identified climate-related risks have affected or are likely to affect the registrants strategy, business model, and outlook. Currently, there are no standards in place which may evoke the need for consistency regarding transparency. The robust list of information required to be disclosed on face value looks pertinent and could offer a framework that would address investor needs. I am for transparency in these matters in order for investors to make accurate decisions based on relevant information. The framework addressing plans has asked for details and descriptions to couple the strategy. This makes for a logical and comprehensive disclosure list. As stated in the fact sheet, a registrant may also disclose information concerning any identified climate-related opportunities would this be a catch all in order to allow the registrant to add additional information outside of the list of proposed required disclosures? I understand this rule making proposal is underway in order to enhance, standardize, and make for a more efficient way to identify risk however, I wonder why the regulation is needed if the issuers are complying to investor demand without more rulemaking. I would think that the investor has the ability to defragment on their own, as you described themselves as already having the cooperation of the issuers. If I am missing a piece of information around this, please advise as I am trying to understand the need for enhancement and standardization of climate related disclosures that already have the cooperation from issuers in addition to the ability for investors to standardize their own framework around disclosures needed.