Sep. 30, 2022
September 30, 2022 \"The Enhancement and Standardization of Climate-Related Disclosures to Investors.\" - What I like about the Rule. GHG emissions metrics could be useful in helping investors assess risk, and I applaud the efforts to provide relevant investors with disclosure information. I observed that the rule states that the objective of this disclosure is not to drive targets, goals, plans, or conduct, but rather to provide investors with the tools to assess the implications of any targets, goals, or plans on the registrant when making investment or voting decisions. This is essential for a healthy economy and a sustainable future. - Where I see room for improvement. There is no specific protocol mandated by the proposed rule, so there could be confusion since not all companies could follow the same standard for measuring results. By making uniform disclosures across all industries, issuers cannot mislead investors or get a greenwashed advantage over their competitors. By enabling investors, analysts, reporters, and the Commission to compare companies' most verifiable and direct climate impacts, it will be harder for companies to misrepresent their impact. A great deal of public information is already available about the multiple products of a single industry, such as the automobile industry. Creating reporting that is more effective and comprehensive will make the truly distinct aspects of reporting better. They will be more meaningful to investors because they will be presented in a distinct way, and therefore the goals will be easier to achieve. Investors can and will use this information in evaluating an issuer's climate narrative disclosure. I recommend taking a voluntary approach because investors and companies in high-risk industries are likely to drive innovation. A company that is willing to take challenging and uncertain steps toward cutting edge innovation should not be penalized for doing so or held accountable for not complying with all the established sustainability goals. - What clarifications, if any, would I like to see. I would like to have more clarification on how the rule could be implemented in the early years, how companies would be educated about how to implement the reports, and how facilitation would be provided. Additionally, I would like to know how the registrant plans to achieve its climate-related goals and transition plan.