Jun. 14, 2022
Secretary Vanessa A. Countryman Countryman, The current practice of permitting companies to voluntarily choose what and how they want to report, and even whether to disclose their climate-related financial risks, makes it impossible for investors and other market participants to 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, mandatory disclosures about their climate-related financial risks within annual SEC filings. We support the inclusion of Scope 1 (business operations) and Scope 2 (purchased energy) GHG emissions reporting. We encourage the SEC require 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. This proposal will fix a broken system of inadequate, not comparable, voluntary climate risk disclosure. It will protect investors, encourage retirement savers to invest in the U.S. capital markets, and provide participants with the climate-related information they need to price climate risk and make investment decisions. Sincerely, Elaine Mayer