This report discusses the continued need for SEC action on climate-related disclosures in light of new California and E.U. requirements.
Jack LienkeNovember 21, 2023
These comments were submitted to the NCUA in response to its request for information on current and future climate and natural disaster risks to federally insured credit unions, related entities, their members, and the National Credit Union Share Insurance Fund. EDF and IPI support the NCUA's intention to promote safety…
Jack LienkeJune 26, 2023
These comments provide observations and recommendations to the Federal Acquisition Regulation Council regarding its proposal to require certain Federal contractors to disclose greenhouse gas emissions and climate-related financial risk and to set science-based targets to reduce their greenhouse gas emissions.
Jack LienkeFebruary 13, 2023
These comments support the Draft Principles as an important step in the Board’s efforts to guide banks to update their risk management practices as needed in light of climate-related financial risks, thereby promoting safety and soundness. We recommend that the Board continue building upon these Draft Principles with final guidance,…
Jack LienkeFebruary 6, 2023
The SEC has proposed a series of new disclosures for investment companies regarding their Environmental, Social, and Governance (ESG) activities. These disclosures would reduce "greenwashing" - a practice where companies misrepresent the sustainability of their investments in order to advertise to investors looking to invest in green funds - by…
Jack LienkeAugust 16, 2022
The SEC has proposed a rule that would better align the names of investment companies with investor expectations, including for Environmental, Social, and Governance (ESG) investment funds, by requiring portfolio distribution requirements for funds whose name connotes a particular investment strategy. The Institute for Policy Integrity submitted comments on the…
Jack LienkeAugust 16, 2022
This letter focuses on two aspects of the justification provided by the Securities and Exchange Commission (SEC) for its proposed rule on climate-related disclosures. First, the letter evaluates the Commission’s rationale for using prescriptive—as opposed to principles-based—disclosure requirements for climate-related financial risk. Second, the letter evaluates the Commission’s rationale for…
Jack LienkeJune 17, 2022
In response to the Securities and Exchange Commission's proposed rule on climate-related disclosures, this letter commends the SEC for conducting an economic analysis that is consistent with relevant case law, and suggests some revisions that would provide additional context and support for the final analysis.
Jack LienkeJune 17, 2022
In her dissent from the Securities and Exchange Commission's proposed rule on climate-related disclosures, Commissioner Peirce describes the SEC as “discover in a long-extant statute an unheralded power to regulate ‘a significant portion of the American economy’” and impermissibly transforming its regulatory role into that of a “Securities and Environment…
Jack LienkeJune 17, 2022
This article argues that the SEC should strengthen mandatory climate risk disclosure rules. A previous version was released as a report in February 2021.
Jack LienkeJune 7, 2022