Ropes & Gray's “The SEC’s Proposed Climate Disclosure Rules – Comment Letter Stats” identifies the sources of the approximately 1,000 substantive comment letters submitted in response to the SEC’s climate disclosure proposal that were not form letters, which represented the vast majority of the approximately 14,000 comment letter submissions.
Noteworthy takeaways from the firm’s analysis of the ~1,000 substantive comment letters include:
- Trade associations/trade groups/industry groups (“trade/industry group”) submitted nearly one-quarter of the letters, followed closely by other organizations (21%) and corporates (20%).
- By industry, Financial Services, Agriculture, and Energy & Extractive accounted for 61% of the trade/industry group letters:
- Corporate submissions were heavily represented by Energy & Extractives industry companies (40%), with the Financial Services and TMT sectors trailing at 16.5% and 13.5%, respectively:
- The bulk of the 133 institutional investor submissions were made by asset managers (76%), with public pension funds and state treasurers at 14%, faith-based investors at 8%, and labor pension funds at 2%.
The memo includes links to many of the comment letters the firm identified as significant, including the Society’s comment letter.
Access additional comment letters here.