Feb. 25, 2023
February 25, 2023 I am writing in support of this regulation. Investors today especially individuals are cognizant of the world around them and the externalities that are not accounted for in business therefore, come to bare on the nation. Many investors value this information and use their investments as a type of voting that allows the more climate-smart companies to be rewarded for their diligence. By virtue of this additional information investors will be afforded the full cost of their investments. This platform will allow for side-by-side comparisons of the investment choices available. Many companies are already making this information available and by creating this regulation, it will place all actors on a level playing field. Open and free markets are predicated on the free flow of information, and this will provide a bit more information that will bring to light issues stemming from the fallacy of the commons issues where everyone is taking advantage of externalities to edge out their completion. In Part 4 paragraph 84 page 143 there is consideration given to utilizing generally accepted accounting principles. I support a uniform system of accounting including a quantitative estimate where practical and qualitative where not practical. In Part 5 paragraph 87 page 145, I agree that a fair value like the requirements of FASB ASC Topic 932-235-50-2 should be established for the environmental disclosure documents. Sarbanes-Oxley Act of 2002 (SOX) established ICFR requirements designed to promote transparency, accountability, and confidence in the financial reporting of publicly traded companies. The environmental disclosure should be subject to the same conditions. On page 152 under GHG Emissions Metrics Disclosure, I agree that disclosure should be in gross terms excluding offsets. This type of information will better inform the investor as to the real cost of their investment. On page 185 paragraph 114, I agree that GHG emissions disclosure for the most recently completed fiscal year and for the corresponding historical fiscal years included in the consolidate financial statements is appropriate.