Sep. 15, 2022
Dear Chair Gensler,
I am writing to thank you for taking steps to make it easier for investors like me to understand climate risk. I retired from the SEC in 2014, but during my thirty-seven years with you I was impressed with the essentiality of investors having access to material information. Although much of our retirement comes from the Thrift Savings Plan, as well as the Civil Service Retirement system for us old-timers, the TSP has a number of funds which investors can choose in allocating their money, and these funds are invested in underlying securities. In choosing among fund, or in making other investment decisions outside of these funds, investors like me want material information about the companies in which we have our money invested.
As an investor looking to maximize my returns, I need to know whether or not a company is preparing to be successful in a low-carbon world. More and more economies are adopting policies and taking steps to align with the goals of the Paris Agreement. Companies not working to reduce their Scope 1, 2 and 3 greenhouse emissions may not be prepared for that future. Without this information, I won't be able to tell what companies are likely to continue to be profitable as the economy transitions to clean energy and which companies could put my savings at risk.
I personally trust the assessments of scientists that climate change is real and our progress in eliminating or minimizing greenhouse gases will have an impact on the future of our world. I also recognize that some people don’t accept the severity or reality of climate change information. Either way, information about the way companies are reacting is material to their effect on our world and the profits they do and don’t make as a result of these decisions. I recognize that sometimes more fossil fuels may be needed short-term, as for the crisis situation in Europe cause by the war in Ukraine, but either way investors deserve the maximum information to navigate our turbulent waters.
Earlier this summer you proposed a rule to require publicly traded companies to disclose "material" Scope 3 emissions. Many investors - both asset managers and individual investors like me - asked you to make this a requirement for all large public companies, and I am hopeful that you will listen to the voices of regular people like me, not just big corporations looking to hide their risks. As you look to finalize these rules, I wanted to thank you for doing everything in your power to ensure that investors like me have the information we need to be able to make smart investing decisions for a low-carbon future. I am looking forward to seeing strong greenhouse gas disclosures, inclusive of Scope 3 emissions, in your final ruling later this year.
Sincerely,
Linda A. Schneider Esq.