Apr. 26, 2022
As a concerned citizen, I am taking the time to write and comment on this disturbing abuse of government authority. I am writing anonymously because I have grave fears that revealing my name or address will cause unwarranted harassment / acts of violence from (i) eco-terrorist front groups and/or (ii) Mr. Gensler's puppet-masters at Goldman Sachs and BlackRock. This proposed rule is simply absurd and truly shocks the conscience. This proposed rule has nothing whatsoever to do with the SEC's statutory authority and Mr. Gensler's staff attorneys should know this intuitively. I will re-submit the comment of Commissioner Hester Peirce because she eloquently details how this rule has nothing whatsoever to do with the SEC's mission. Moreover: she details very persuasively how the supposed \"good intentions\" of the rule will ultimately harm investors by forcing public company CEOs/CFOs to focus an unwieldy amount of time of eco-compliance (instead of on more important matters like profitability and/or dividends). https://www.sec.gov/news/statement/peirce-climate-disclosure-20220321 I think Hester Peirce's commentary is so eloquent and well-supported that in it of itself it should cause the SEC to withdraw this rule. However: I will re-submit because I would like to make it a matter of public record that average concerned citizens share this viewpoint and this is not simply an academic debate within the SEC staff attorney boardroom. I would also like to add an additional comment in reference to her reference #41, which I will reproduce in full below: Letter from Julia Mahoney and Paul Mahoney, University of Virginia School of Law (June 1, 2021), https://www.sec.gov/comments/climate-disclosure/cll12-8855236-238441.pdf (arguing that, in advocating for additional ESG disclosures, some large institutional investors and asset managers, rather than operating from financial motives, may be striving to achieve political and social change through the capital markets) While Hester Peirce does not 'name names', I will. One should not be surprised that this is the work of a 'Government Sachs' alum, Gary Gensler. One could make a compelling intellectual and legal case that Gary Gensler never should have been allowed to assume office given his inability to impartially perform the duties of his role at the SEC without a very real conflict of interest with his former employer Goldman Sachs. The extent to which the Goldman Sachs organization has infiltrated every government agency is truly disturbing when one considers the extent of wrongdoing at Goldman Sachs. What is even more disturbing is how Goldman Sachs has now decided to throw its full weight behind radical environmental causes as a way to offset its 'sins' during the financial crisis. If there had been any level of justice in this country (and world), Goldman Sachs would have been stripped of its banking license and liquidated. When one examines the level of misconduct at Goldman Sachs, the 1MBD scandal really speaks to the character and ethics of the firm. Let's be honest here. What this rule 'really' does is give the bankers and attorneys at Goldman Sachs (and BlackRock) powerful ammunition to destroy the lives of countless average citizens and companies that support small-town industrial communities and small-town mining towns in the REST of the United States (i.e., not New York City). What this rule 'really' does is subvert American democracy so that the corrupt bankers and attorneys in New York City and San Francisco can rule every other state by executive fiat. Whatever the talk about 'good intentions' and 'social good', that's what this rule's practical effect is. The only people who will benefit from this rule are the environmental attorneys and consultants in NYC and SF who will now charge even higher billable hour rates. By the twisted logic that prevails in this country, apparently Mr. Gensler's definition of 'social justice' is a scenario where Goldman Sachs makes trillions of dollars and the average citizens goes ba nkrupt. If this rule goes into effect, maybe Larry Fink should be named President of the United States as well as High Commissioner of the United Nations. I will conclude by saying: this rule should not go into effect. There is no need to enrich Goldman Sachs and BlackRock even more. There is no need for the SEC to do the exclusive bidding of these organizations. It is also my hope that Gary Gensler steps down as this rule demonstrates that he is fundamentally incapable of performing his duties at the SEC without doing the exclusive bidding of Goldman Sachs. The time has come and past for Goldman Sachs to control the US economy.