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Agency FilingFinancial DisclosureFinancial RegulationRegulatory Activities

Comments to the FAR on the Disclosure of Greenhouse Gas Emissions and Climate-Related Financial Risk

These comments support the Federal Acquisition Regulatory Council's proposed rule on the disclosure of greenhouse gas emissions and climate-related financial risk. The Proposed Rule is an important step to safeguarding and promoting efficient and economical procurement, and ensuring resilience of essential government functions in light of escalating climate-related financial and…
Stephanie Jones
February 13, 2023
Agency FilingFinancial DisclosureRegulatory Activities

Comments to the Federal Reserve on Principles for Climate-Related Financial Risk Management for Large Financial Institutions

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,…
Stephanie Jones
February 6, 2023
Agency FilingFinancial Regulation

Comments to the FIO on Climate-Related Financial Risk Data Collection

These comments support the Federal Insurance Office's proposal to collect information from property and casualty insurers regarding current and historical underwriting data on homeowners' insurance. This data collection would mark a critical step towards understanding how climate-related disasters may affect the availability and affordability of insurance for U.S. householders. This…
Stephanie Jones
December 20, 2022
Blog/News ArticleFinancial DisclosureFinancial Regulation

Widespread Support for the SEC’s Proposed Climate Risk Disclosure Standards

As shown in the quotes collected in this blog, a proposal from the Securities and Exchange Commission (SEC) that would standardize public companies’ disclosures of climate risk information is getting strong support from the general public, investors, companies of various sizes across a wide range of sectors, law and business…
Stephanie Jones
September 13, 2022
Agency FilingFinancial DisclosureFinancial Regulation

Comments to the ISSB on Climate-Related Disclosures Exposure Draft

These comments support the Climate-Related Disclosures Exposure Draft of the International Sustainability Standards Board (ISSB), which will provide investors around the globe with the information necessary to inform their investment decisions. The comments commend the ISSB’s goal of creating a global baseline and encourage the ISSB to consider certain modifications…
Stephanie Jones
July 29, 2022
Agency FilingFinancial DisclosureFinancial Regulation

Comments to the SEC on Reasoned Explanation for Its Proposed Rule on Climate-Related Disclosures

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…
Stephanie Jones
June 17, 2022
Agency FilingFinancial DisclosureFinancial Regulation

Comments to the SEC on Regulatory Precedents for Its Proposed Rule on Climate-Related Disclosures

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…
Stephanie Jones
June 17, 2022