Jun. 14, 2022
Secretary Vanessa A. Countryman Countryman, As an investor, I need to be able to work with my investment managers to make intelligent decisions about my investments, especially now as climate change and climate risks have big impacts on markets. This means it's critical for me to have access to standardized information about public companies' vulnerability to climate change, their current greenhouse gas emissions, how they plan to manage climate risks, and how they will follow through on public climate commitments. Right now, companies can voluntarily choose what and how they report this information—including whether or not they'll disclose their climate-related risks at all. This means investors like me have an impossible task in understanding the comparable risks and opportunities of different investments. That’s why I 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. I support the inclusion of Scope 1 (business operations) and Scope 2 (purchased energy) GHG emissions reporting, in absolute and intensity terms. We 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. This proposal 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, Carolyn Servid