A comment letter on the SEC’s proposed climate disclosure rule

Here’s a note from Bob Eccles about this comment letter sent to the SEC about it’s proposed climate disclosure rulemaking (also see this comment letter from 15 former senior SEC officials that argues against the notion that the SEC never had the authority to mandate climate disclosure rules, as described in this note from Shiva Rajgopal):

In a memo published today, Wachtell, Lipton, Rosen & Katz announced that it has submitted a comment letter regarding the SEC’s proposal for “The Enhancement and Standardization of Climate-Related Disclosures for Investors.” The signatories to this letter are Alan Beller, Daryl Brewster, David A. Katz, Carmen Lu, Leo Strine, and me. We received enormously helpful input from Richard Barker and John Coates.

The memo notes “The substantial risks and challenges that climate change presents to our nation’s businesses, investors, and economy are undeniable.” It also points out that “The real question for those who care about our companies and their investors is how we act most cost-effectively to address this critical issue.” Towards that end our letter makes some constructive suggestions about how to make the proposed good rule even better.