Agency: Securities and Exchange Commission (SEC)
Date Filed: 6/17/22
Docket No: S7-10-22
The Electric Power Supply Association submitted comments in response to the U.S. Securities and Exchange Commission’s March 21, 2022 proposed rule to require companies to include certain climate change-related disclosures in their registration statements and periodic reports (“Proposed Rule”). The recommendations outlined in the comments are offered to establish an efficient and informative reporting process to provide climate-related transparency to the public, investors, and government. EPSA’s comments, examples, and suggested modifications are focused on the key provisions of the Proposed Rule that pose the greatest concern and are not necessarily inclusive of all concerns that EPSA or its member companies may have with the Proposed Rule. EPSA recognizes the SEC’s intention through the Proposed Rule to provide investors with climate change disclosures. Many companies, including EPSA member companies, have been voluntarily providing climate change and sustainability disclosures for some time, and practices continue to evolve and improve as companies take into account market feedback and build on their capabilities and resources. However, EPSA believes certain aspects of the SEC’s proposed rules would not provide investors with decision-useful information, and at the same time create significant, undue burdens on companies. EPSA urges the SEC to make targeted revisions in these areas and in so doing, develop a Final Rule that would facilitate more efficient and effective disclosures, benefitting both companies and investors.