Jun. 12, 2022
This proposed rule does not serve US citizens. It imposes additional financial burdens on US corporations and provides no direct benefit to either the corporations or the citizens of the US. The proposed rule appears to primarily benefit international investors by reducing their due diligence research costs to acquiring investments. Due diligence is required of the investor and the costs of such discovery should be born by that investor. The proposed rule appears to be based primarily on the demands of foreign investor groups which desire US corporations to bear the cost of their responsibility for exercising due diligence on behalf of their clients. This does not serve the interests of US citizens or US corporations; therefore it should not be given further consideration by the Security and Exchange Commission. The proposed rule relies upon the GHG Protocol for disclosing greenhouse gas emissions. This protocol is flawed as it based on a consensus of non-scientific groups rather than actual fact-based measurement of greenhouse gas emission and their effects. No US department or US state has adopted the GHG Protocol, which indicates that it is not useful as a source of actionable facts. This proposed rule will result in increase costs to US corporations which will be passed through to the US consumer, especially minorities and women. These costs should be born by the investor, not US citizens.