Subject: S7-10-22
From: Todd
Affiliation:

Apr. 14, 2022

As a stakeholder, I urge the SEC to Close the Loophole in this rule that could potentially allow companies to omit some (or most) of their emissions from disclosures. 


This new draft rule for climate risk disclosure is an important first step in protecting investors. It’s a great start to making companies more transparent about their greenhouse emissions and will allow millions of Americans to make more informed investment choices – in everything from retirement funds to college savings accounts. But the proposed rule doesn’t go far enough. By leaving it up to companies to determine the significance of Scope 3 emissions – particularly when the rule can also shield issuers from liability if they provide false or misleading information – the proposed rule may allow companies to omit some (or most) of their emissions from disclosures. Please strengthen the final rule to address these loopholes to increase transparency for Americans and protect our planet.