Jun. 16, 2022
June 16, 2022 It is unfair to investors that companies they invest with do not have safeguards and disclosures around events that 98% of scientists say will continue to happen. Each company must assess how it will be impacted if they haven't been hit already. Q15. Yes. plastics, land use change and deforestation, and just transition for workers and Indigenous rights. Q24. Yes, information about the use of carbon offsets and RECsincluding the types of projects financed. there needs to be quality control check on offsets. Q25. Yes. wouldn't any investor want to know this? how will climate affect an insurance company. how will climate affect businesses that will under water for sea level rise. how will climate affect buildings near forested areas catching on fire/ Q48. Yes. if they can't articulate a plan, they probably won't be able to adapt under those scenarios. Q72. yes. if they can't finance the said transition, they won't be able to do it. Q98. (Pg. 184) Should we require a registrant to disclose its Scope 3 emissions for the fiscal year if material, as proposed? No. Scope 3 emissions disclosure should be mandatory for all large accelerated filers and accelerated filers, and should not be based on self-determined materiality. Should we instead require the disclosure of Scope 3 emissions for all registrants, regardless of materiality? Yes. There is a long history of SEC requiring disclosures that are important for investor protection and fair and efficient markets, without regard for materiality on a case-by-case basis. SEC Commissioner Lee noted last year, In practice Regulation S-K has, from the outset, required periodic reports to include information that is important to investors but may or may not be material in every respect to every company making the disclosure.41 We have done this, for example, with respect to disclosures of related party transactions,42 environmental proceedings,43 share repurchases,44 and exe cutive compensation.45 Q133. (Pg. 224) Should we provide a safe harbor for Scope 3 emissions disclosure, as proposed? No, Q135 (Pg. 243)The more they process and exampine, the emissions from the different scope levels, the more aware they will be of what is happening. Yes, Q168. Um. Yes. Q169. Yes. Q171. Yes. we need to know if they are on track.