May. 09, 2022
Dear Secretary, Securities and Exchange Commission Vanessa A. Countryman, I am a fifth-generation rancher. I recently submitted comments to the SEC with concerns about their proposed climate disclosure rule, File Number S7-10-22. The SEC is rushing to establish a rule that raises huge issues and I have shared these concerns with the SEC. The SEC proposed rule is 510 pages long, with 1,068 technical footnotes and 750 direct questions, but the SEC has only given farmers and ranchers who will be impacted 39 days to review and comment. I do not believe this is representative of a good and transparent government. It is impossible to understand the scope and detail of what will be required of my family's ranch by this rule given the very limited comment period. Unlike corporations currently regulated by the SEC, farmers and ranchers, like myself, don’t have a team of compliance officers or attorneys dedicated to handling SEC compliance issues. There are many questions about how our privacy will be protected, what the substantial costs and legal liabilities will be, and whether reporting requirements will disqualify small, family-owned farms and ranchers from doing business with public companies, or companies that supply public companies, which would have the unfortunate effect of causing more consolidation in agriculture. This is a clear example of overreach by the Securities and Exchange Commission. I would greatly appreciate your help and advocacy in addressing this overreach. Regards, Katelin Spradley 26 Mary Ln Mcintosh, NM 87032