SEC Submission

Under the previous US Administration, the potential for climate impact mitigation progress was lost. While investors and businesses continued to address climate, advances were blunted by lack of appropriate US government intervention. This motivated Boston Common to sign onto the 2021 Global Investor Statement on Climate Change supported by 456 investors with over $41 trillion in assets.

There is a growing demand and need for broad and consistent climate disclosure by issuers worldwide including the United States – a first for the U.S. as highlighted in the recent Financial Stability Oversight Council (FSOC) report. One of the report’s key recommendations was to “(e)nhance climate-related disclosures to give investors and market participants the information they need to make informed decisions, which will also help regulators and financial institutions assess and manage climate-related risks”.

Boston Common has been part of individual and collaborative discussions with the SEC over the past year and has provided written feedback to the SEC in June 2022 and November 2021. In our meeting and subsequent follow up with Chairman Gensler and the SEC in November 2021 we shared key points summarized as follows:

  1. Measuring Scope 3 is essential
  2. Investors need backward and forward looking disclosure
  3. Assurance on climate accounting practices is necessary for issuers in a tier approach or timeline
  4. US Financial Regulatory Systems must be aligned

We are hopeful that the SEC will incorporate this feedback and show support for just transition and climate strategy policy alignment. Follow the links below for the full text of our outreach to the SEC and our submission on mandatory climate disclosure.

June 2022

June 2021

Published On: June 23, 2022Categories: From the Commons