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. The issue of companies claiming assets valued without estimating the risk that so-called "reserves" may be unusable in future may well mislead investors like me, when the companies likely will provide more correct information to lenders. I vote my stocks to encourage less burning of fossil fuels because of the climate change that creates. But the boards are not transparent about the impacts on future plans and incomes, nor am I sure they are making plans to protect the environment by pursuing better ways of providing energy and doing business. I am reliant on my savings and need to have better information on the impacts on my retirement income. 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. 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. Jo Ann Duman