Sign and Send a Comment Supporting the SEC’s Proposed Disclosure Rule on Corporations’ Climate-related Financial Risks!

The Securities and Exchange Commission (SEC) took a much-needed step forward by introducing new proposed financial protections for investors, including everyday people like nurses, teachers, and firefighters with retirement plans like a 401K, pension or IRA, from climate-related financial risk.

These mandatory, standardized disclosures would give investors insight about a public company’s vulnerability to climate change and current greenhouse gas emissions. It would also require companies to reveal plans to protect investors (and their retirement savings) from these risks. We’re also pushing for the proposed rule to be stronger, by including disclosures around environmental justice, Indigenous rights, a just transition for dislocated workers, and community-level impacts.

This is important because public companies can currently choose what they want to disclose about their climate-related financial risks, and even whether or not they want to disclose at all, leaving investors in the dark. Unless this information is filed with the SEC, corporations can continue greenwashing their impacts and making vague climate commitments without being held accountable.

Wall Street and fossil fuel firms are already lobbying against the SEC’s proposed disclosures, but if we speak out in support by submitting our comments to the SEC, we can help ensure that information on climate risks is comparable and freely available to all investors and market participants.


Our Comment to the SEC:


To the Securities and Exchange Commission and SEC Chair Gensler:

Investors–including working people like nurses, teachers, and firefighters who have a retirement plan like a 401K, pension, or IRA–and their investment managers need access to standardized, comparable information about public companies’ vulnerability to climate change, their current greenhouse gas (GHG) emissions, and their plans to manage climate risks and make good on their public climate commitments.

The current practice of permitting companies to voluntarily choose what and how they want to report, and even whether or not they want to disclose their climate-related financial risks, makes it impossible for investors and other market participants to fully understand and compare the risks and opportunities associated with different investments.

That’s why we support the Securities and Exchange Commission (SEC)’s recent proposal (87 FR 21334; File No: S7-10-22) to require public companies to make standardized, mandatory disclosures about their climate-related financial risks within annual SEC filings.

We support the inclusion of Scope 1 (business operations) and Scope 2 (purchased energy) GHG emissions reporting, in absolute and intensity terms. We strongly encourage the SEC to strengthen the final rule by requiring Scope 3 GHG emissions (e.g., product and supply chain emissions) disclosure from all large registrants, and to include disclosures around environmental justice, Indigenous rights, a just transition for dislocated workers, and community-level impacts.

This proposal is a vital step forward to fix a broken system of inadequate, not comparable, voluntary climate risk disclosure. It will protect investors, encourage prospective retirement savers to invest in the U.S. capital markets, and provide market participants with the climate-related information they need to accurately price climate risk and make well-informed investment decisions.

Sincerely,