Mar. 31, 2022
Dear Chair Gary Gensler, This is the season for corporate annual meetings. I notice in the voting for shareholder resolutions about climate change that 100 % of the time the board of directors day to vote against these resolutions. As our government's chief financial regulator, your agency is responsible for ensuring public companies respond to investors’ need for information that helps them protect their investments. Passage of your agency’s new rule on the Enhancement and Standardization of Climate-Related Disclosures for Investors (S7-10-22) is a critical step in fulfilling your mandate. As an expert in my field, I’m extremely concerned about how heat-trapping emissions and rapidly worsening climate impacts pose a significant risk across many areas of human society—including to our financial and economic systems. I urge the Commission to adopt a strong, comprehensive rule without delay. In particular, the final rule should mandate and standardize disclosure by publicly listed companies of ALL heat-trapping emissions associated with corporate operations, products, and supply chains, as Scope 3 emissions can account for 80-90 percent of companies’ total emissions in some sectors. Swift adoption, implementation, and enforcement of a strong rule will help businesses meet the demands of international capital markets and ensure investors have consistent and comparable data to make fully informed decisions and hold corporations accountable for their impact on the climate, their plans to mitigate those impacts, and their progress in achieving climate-related goals and targets. Please protect our financial system from climate-induced risk by passing a strong, science-based climate disclosure rule as soon as possible. Sincerely, Mr. Steven Gary Seattle, WA 98118