Jun. 14, 2022
Secretary Vanessa A. Countryman Countryman, I am 71 years old and living on Social Security benefits and savings, some of which is currently invested in the stock market. I strongly 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, mandatory disclosures about their climate-related financial risks within annual SEC filings. We all know that the current situation of leaving these disclosures to the whims of public companies will result in nothing being reported. It is also extremely important that each company be required to report the same information including the company’s’ vulnerability to climate change, current greenhouse gas emissions, and their plans to manage climate risks, and in a standardized mandatory form. Investors (including real people such as me!) and other market participants need to be able to fully understand and compare risks, opportunities associated with various investments. I support the inclusion of Scope 1 (business operations) and Scope 2 (purchased energy) GHG emissions reporting, in absolute and intensity terms. I strongly encourage the SEC to strengthen the final rule by requiring Scope 3 GHG emissions (e.g., product and supply chain 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. It is a vital step forward to fix a broken system of inadequate, not comparable, voluntary climate risk disclosure. It 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, Joyce Hyne