Jun. 15, 2022
Secretary Vanessa A. Countryman Countryman, IT IS UNACCEPTABLE FOR COMPANIES TO WITHHOLD VITAL INFORMATION FROM INVESTORS. Investors are not just the super rich. They include hard-working average-income people like nurses, teachers, and firefighters who have a retirement plan like a 401K, pension, or IRA. They and their investment managers need access to standardized, comparable 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. That information is vital to understanding a company's future financial health and potential downside risk! 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 fully understand and compare the risks and opportunities inherent in different investments. The current practice, is, in fact, an open invitation to defraud investors by withholding vital information related to financial risk and financial health. That’s why I strongly support the SEC’s recent proposal to require public companies to make standardized, mandatory disclosures about their climate-related financial risks within annual SEC filings. (The proposal is 87 FR 21334; File No: S7-10-22) I strongly support including Scope 1 (business operations) and Scope 2 (purchased energy) GHG emissions reporting, in absolute and intensity terms. I also strongly encourage the SEC to: 1. strengthen the final rule by requiring Scope 3 GHG emissions (product & supply chain emissions) disclosure from all large registrants, and 2. include disclosures around environmental justice, Indigenous rights, a just transition for dislocated workers, and community-level impacts. The current system is broken and leaves us investors with incomplete, inaccurate and deceptive information about risk in our financial investments. This proposal is a vital step that will fix our broken system of inadequate, non-comparable, up-to-a-company's-whim disclosures about climate-related risk. This proposal will: 1. protect investors 2. encourage prospective retirement savers to invest in the U.S. capital markets, and 3. provide market participants with the climate-related information they need to accurately price climate risk and make well-informed investment decisions. Sincerely, Nancy Campbell