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June 17, 2022

We Support the SEC’s Climate-Risk Disclosure Proposal, a Very Strong Measure That Can Be Made Even Better

WASHINGTON, D.C.—Legal Director and Securities Specialist Stephen Hall issued the following statement on the filing of Better Markets’ Comment Letter to the Securities and Exchange Commission in response to the agency’s proposal to enhance the disclosure of the climate-related risks facing companies:

“No company will be able to escape the financial consequences of climate change, and ultimately, how companies assess and respond to climate-related risks will be a key determinant of their business prospects.  This is why investors have for years been demanding that the companies they own provide them with reliable, consistent, and comparable information on climate-related risks and opportunities. That is also why we support the proposed rule and why it is a perfect example of the SEC exercising its broad statutory authority to mandate disclosure by companies for the protection of investors and the public interest.

“Although we have known that the Earth’s climate has been warming for decades, the past several years have made the devastating consequences of failure to address climate change all too clear.  From more frequent and powerful hurricanes to devastating wildfires, climate change is already having a costly and deadly impact across the world.  Moreover, to avoid even more devastating consequences, policymakers around the globe are implementing drastic measures to curb greenhouse gas emissions.  Virtually every company faces serious financial consequences as these undeniable trends unfold, and that’s why investors need to know more about how companies are responding.

“Given the significant investor demand for climate-risk disclosures and the commonsense notion that virtually every companies’ financial performance will be impacted in some way by climate change, it is clear that mandating climate-risk disclosures is well within the SEC’s broad mandate.  Those who claim that the SEC has exceeded its authority and waded into the realm of environmental policy-making either don’t understand the securities laws or are cynically trying to defeat a measure they just don’t like.  Requiring disclosure of material information for the benefit of investors has been the bread-and-butter regulatory tool of the SEC since it was created 89 years ago, and this proposal is no different.

“In our comment letter, we explain in detail how the SEC has clear authority to mandate climate disclosures for the protection of investors.  In addition, we urge the SEC to consider using its broad authority to close some loopholes in the proposal, particularly those related to independent verification of a company’s reported emissions and to reporting of indirect emissions.  If the SEC heeds these suggestions, a very good proposal will become an even stronger final rule.”

Read our full comment letter here.


Better Markets is a non-profit, non-partisan, and independent organization founded in the wake of the 2008 financial crisis to promote the public interest in the financial markets, support the financial reform of Wall Street and make our financial system work for all Americans again. Better Markets works with allies—including many in finance—to promote pro-market, pro-business and pro-growth policies that help build a stronger, safer financial system that protects and promotes Americans’ jobs, savings, retirements and more. To learn more, visit

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