Jun. 16, 2022
June 16, 2022 Dear Commissioners, I am writing in support of your proposed rule to require disclosure of climate risk and reporting of greenhouse gas emissions. Investors need standardized information about global warming pollution emission to make informed decisions. In the EU, companies are already facing these requirements. According to KPMGs 2021 CEO Outlook, in a world of Covid, global supply chain disruptions and increased political instability, climate change still ranked among the top 5 risks to growth over the next three years. The 2022 World Economic Forum Executive Opinion survey found that climate action failure was the number one long-term threat to the world, and the risk with potentially the most severe impacts over the next decade. Study after study reveals the costs of climate change now, including in the US, a staggering rise in the damages from extreme weather events, topping $750 billion over the last five years. All of these mounting costs and create risks, and also opportunities for carbon innovators. Financial markets are increasingly focused on climate risk. At the UN climate meetings in December 2021, The Glasgow Financial Alliance for Net Zero (GFANZ), representing over $130 trillion of private capital, committed to transforming the economy for net zero. These commitments, from over 450 firms across 45 countries, could potentially deliver the estimated $100 trillion of finance needed to achieve net zero over the next three decades. Separately, global investors managing over $130 trillion of assets, including Fidelity, JP Morgan and BNP Paribas, have called on companies to disclose a net-zero transition plan, identify the director leading the plan, and provide a way for investors to vote on progress against the plan annually. Financial markets are demanding credible risk disclosure and emissions information. Please move forward in issuing a strong, durable set of regulations.