Subject: S7-10-22 The Enhancement and Standardization of Climate-Related Disclosures for Investors
From: Stuart Morgan
Affiliation:

Mar. 25, 2022

Proposed Rule S7-10-22 should never be implemented by the SEC!
 
The proposal to submit US Publicly traded companies to this rule is 1) Arbitrary in its scope and enforcement, 2) Political in its Purpose, and 3) Anti-Competitive in its Effect to US based companies!
 
The SEC already doesn’t submit foreign companies (especially Chinese Based Companies) to the same accounting regulations that US Based companies have to abide by.  That gives foreign companies an advantage, and a way to scam investors.  I owned shares in Chinese based “China Energy Savings Technology”, which one day just quit trading on the US exchanges.  When it finally reopened for trading many months later, I had lost about 70% of my investment.  If that company had to follow the same accounting rules that US companies have to, then I would have had a better chance of knowing that they were misleading investors about their company’s finances.
 
This rule would not only be costly for companies to try to comply to, but they would have to guess on many future climate outcomes.  So in order for US Public companies to comply to the rule they have to estimate future events and in doing so that ultimately leaves them open to more litigation.  Litigation when their guesses are wrong.  Litigation when their estimates of future events and outcomes are wrong.
 
The whole Climate Change movement in our country is propped up on the idea that CO2 is bad.  And yet, CO2 is a required part of our bodies and environment, and without it we would not be alive.  Plants on earth NEED CO2 to live!  Not to mention that most of the CO2 is actually formed naturally by the oceans.  The Earth used to be warmer that it currently is, and the dangers to mankind are really much more severe if the Earth was to cool down.  We can survive a degree or two of warming, but many not be able to survive many colder degrees.  So enforcing some Climate Change rules on Public companies is really just a form of political control and the SEC has no business pushing such rules!
 
STOP THIS MADNESS—STOP THIS RULE!
 
More importantly, the SEC needs to FOCUS on making Foreign Companies follow the same Accounting Rules as US Based Companies have to follow!
 
 
Stuart Morgan