Subject: S7-10-22: WebForm Comments from STS Software LLC
From: STS Software LLC
Affiliation: President CEO

May. 12, 2022

May 12, 2022

Self-reporting while practical needs to be traceable and verifiable.

1- Investors need to be able to verify that the indicators reported via the SEC are indeed based and supported by operational data collected on a continuous basis throughout the year by the different company's information management systems. What is the minimum level of verification or auditability of the reported data on environmental indicators and sustainability metrics that the SEC will require?  Will the metrics and indicators reported by companies be verifiable?

2- Companies should provide along with the metrics reported a method for investors to verify and monitors said indicators continuously in digital form. Such method should be codified and required in the rule.

3- In the event that an investor(s) cannot verify or detects discrepancies with the accuracy of the metrics reported to the SEC by the company the rule should provide for a digital method for the investor to request clarification or verification of the data reported.