Organizations Involved: Environmental Defense Fund, Institute for Policy Integrity
Source: Securities & Exchange Commission

Abstract

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 using various third-party frameworks and definitions to structure and inform the Proposed Rule. The letter finds that the SEC has provided adequate explanations for its choices and recommends additions that could further bolster the SEC’s explanations in the final rule.

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