May. 10, 2022
Dear SEC, Have read your 490 Page proposed regulation to "help me" as a private investor for climate related disclosures. In summary: DO NOT APPROVE THIS REGULATION AS PROPOSED. As a private investor, I may not be in the same class as a Larry Fink (Thank God) or one of the 615 Investors controlling $60 Trillion in Assets (Ref Note 23). But I do know this regulation is NOT in the Top 10 items I review when I purchase Stock in a company traded in the Stock Market and subject to the SEC Regulations. And I find this another example of the government (in this case, the SEC) causing American companies to expend extraordinary financial resources causing a disadvantage against their global competitors (who do not have to pay for this disclosure). What do I really need to know as an investor? Simply stated: 1. Does this company meet all the Climate Related regulations from the US and State governments? YES or NO. If NO, explain WHY. 2. Are there potential company climate related risks that will require company expenditures to resolve? YES or NO... If NO, please define Projected expenditure values against future sales and profits. THE END. (HINT: I can assure you I will not read any multiple paged Climate-Related Disclosure offered by a company if these two questions are answered in the management letter to the investors.) Personally, and unlike Mr Fink and the 100+ group, any additional GOVERNMENT required expenditures beyond answering these two questions are unnecessary, unwanted, and unwarranted by small investors. Either the company is working within climate regulations, or it is not. And if it is not, then the company management and the company investors need to resolve the financial issues to meet any climate regulations. On Page 9 of the proposal, I find the following sentences: "Investors need information about climate-related risks—and it is squarely within the Commission’s authority to require such disclosure in the public interest and for the protection of investors—because climate-related risks have present financial consequences that investors in public companies consider in making investment and voting decisions." Just because it is within the Commission's authority (or not), I find it offensive that the SEC feels it has to become a third party standing between the company management and the company's investors. I see no value in the SEC executing an implied authority just because it can. Bottom Line: I propose this regulation be reduced to two pages directed to answer my two questions above that guide my investment criteria. Any effort to go beyond the two questions is a waste of effort (man-power and financial) and my company stock's value. Sincerely, Jay Stevenson, private investor