April 25, 2022
I cannot say that I am an expert, either in the field of ESG or on this particular Rules Change Proposal. However, I have read through the Proposed Rule Change document (does it really have to be 490 pages?). The main conclusion I draw is that there are two parts to the Proposal: 1) reporting of emissions-related measures and 2) reporting of climate-related risk measures.
As an Investor, I'm more interested in the second part of the Rule Change Proposal. That is, what impact will \"climate events and contingencies\" have on the business' operations. The examples described in the Rule Change document seem pertinent and relevant.
Again, as an Investor, I am much less concerned with the reporting of emissions-related metrics. These types of metrics seem outside the scope of the SEC and are not of primary interest - as an Investor. Reporting these types of metrics appear to be geared towards modifying behaviors of Issuers, rather than providing decision-making information to Investors.
I also have an overarching concern with the onerous nature of the reporting requirements. I had a front-row to the various Banking Regulation reporting requirements implemented over the past several years. While I do not have specific empirical data, I believe it is well known that those requirements were incredibly expensive. I also know that those reporting requirements did not always have their intended effect.
I submit that the Rule Change should be changed to:
1) eliminate the emissions reporting requirement
2) reduce the financial impact to Investors of complying with the Rule Change