Subject: File Number S7-17-22 RIN 3235-AM96 ESG Investment Practice Comments
From: Joyce Dillard
Affiliation:

Aug. 17, 2022

Since ESG is a non-financial factor,  it is unclear how you define the parameters that apply.  What geographic areas are involved including countries. 


How do different geographic areas differ in laws, regulations and taxes.  What offsets are offered and who benefits 


How are the funds investment decisions applied to any mitigation plans. How is progress determined. How are responsible agencies identified.  How can the investor verify any facts.   


Please describe what summarize in a few sentences means in disclosure when ESG requires oversight and verification, 


You refer yo GHG emissions.  Are you including water vapor. 


This proposal has little to do with ESG and only adds unsubstantiated burdens to any disclosure, 


Joyce Dillard  
Los Angeles CA.  
Pacific Daylight Time