Jun. 14, 2022
Secretary Vanessa A. Countryman Countryman, Both investors who have a retirement plan like a 401K, pension, or IRA, and their investment managers need access to standardized, information about public companies’ vulnerability to climate change, their current greenhouse gas (GHG) emissions, and their plans to manage climate risks and make good on their public climate commitments. The current practice of permitting companies to voluntarily choose what and how they want to report, and even whether or not they want to disclose their climate-related financial risks, makes it impossible for investors and other market participants to understand and compare the risks and opportunities associated with different investments. That’s why we support the Securities and Exchange Commission (SEC)’s recent proposal, 87 FR 21334; File No: S7-10-22, to require public companies to make standardized disclosures about their climate-related financial risks in annual SEC filings. I support the inclusion of Scope 1 (business operations) and Scope 2 (purchased energy) GHG emissions reporting. I encourage the SEC to strengthen the final rule by requiring Scope 3 GHG emissions disclosure from all large registrants, and to include disclosures around environmental justice, Indigenous rights, a just transition for dislocated workers, and community-level impacts. This proposal will protect investors, encourage prospective retirement savers to invest in the U.S. capital markets, and provide market participants with the climate-related information they need to accurately price climate risk and make well-informed investment decisions. Sincerely, Stephen Lane