Apr. 12, 2022
I write this email as a private citizen, taxpayer, and an accredited investor who manages my family’s investment portfolio of equities, bonds and mutual funds. I request at least a 60-day extension to the current 60-day public comment period for Proposed Rule on Enhancement and Standardization of Climate-Related Disclosures for Investors (File No. S7-10-22). I plan to submit a response to the proposed rules but will require additional time to assess the totality of information and to incorporate my feedback into a formal submission. I observe the following regarding the Commission and its proposed rules: They encompass more than 500 pages They include over 200 individually numbered questions; yet the vast majority of the individually numbered questions contain multiple additional questions, which easily brings the count to in excess of 600 total questions asked by the Commission. The Commission provided a 90-day comment period on its initial request for public input on climate-related disclosures, which was not nearly as granular or prescriptive. The Commission took approximately nine months to author and propose the very rules on which it now seeks comment. They propose detailed disclosures, some of which will be subject to audit as soon as the 2023 10-K. The initial request for comment on climate-related disclosures did not include such detail, low thresholds or condensed timelines. I, like other private citizens, must balance my personal and professional lives when allocating my time to a voluntary activity such as this. Reading, assessing, understanding & crafting a cogent response to 500+ pages of proposed rules/analyses will simply take more than 60 days to accomplish. I highlight again how the Commission took the majority of a year to craft these rules yet offers a meager 2 months for a public comment period. With such a short timeline, one can reasonably assert that the Commission intends to ram these rules through or foreclose debate before the general public realizes what they require. I trust the Commission will make the only rational decision it can, which is to extend the comment period deadline. Respectfully, Gregory Farris, CPA Fort Bend County, Texas