Subject: S7-10-22: WebForm Comments from JVW
From: JVW
Affiliation:

Jun. 10, 2022

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 \***June 10, 2022

 Dear Sirs, I am a typical small investor and I am against your proposal for numerous reasons.  A few are:
There does not seem to be a great demand, other than from institutional investors and those that are really invested in climate change to force companies to track and disclose this information.

Investors like myself are mainly concerned about returns and these proposed rules, if adopted would reduce the rate of return because extra money would be needed for new systems and people to keep track of all the information you propose.

Currently companies are voluntarily reporting \"ESG\" information if they see fit and investors who are interested in this information are probably already investing in these companies

The proposed rules only focus on the \"risk\" that MAY come about due to climate change.  When some companies see \"risk\" other companies may see \"opportunity\" and this proposal does not even mention this possibility.  Why is that?  Is it because this agency is attempting to force companies to conduct their business in a way and in industries of which you approve?  Respectfully, that is not what the SEC's charter gives you authorization to do.

I also believe that these proposed rules are unworkable for all but the largest companies and from the comments I've read about the proposed accounting rules for companies, these also will cause multiple problems for smaller public companies.

As I said in the beginning, I do not believe these proposed rules should take effect.