In her remarks yesterday before the Brookings Institution, SEC Commissioner Hester Peirce shared her seasoned perspective on the SEC's role in ESG investing and associated corporate disclosure. Among other things, the thoughtful speech includes cites to numerous comment letters submitted in response to former Acting Chair Allison Herren Lee’s request for input on climate change and other ESG disclosures, including the Society’s comment letter as respects: (i) the unlikelihood of SEC-mandated ESG disclosure meaningfully reducing demands for information from ESG raters, and (ii) suggesting the SEC consider updated or additional interpretive guidance, in lieu of imposing new disclosure requirements, to assist companies in evaluating material climate risk and other ESG information for disclosure.
Commissioner Peirce’s speech also quotes certain remarks made by Society Sustainability Practices Committee Chair and Vice President, Chief Sustainability Officer and Group General Counsel, The Travelers Companies, Inc., Yafit Cohn, before the SEC’s Asset Management Advisory Committee earlier this year, regarding the multiple, potential adverse consequences of the SEC straying from its core mission by promulgating values-based rather than shareholder value-based disclosure requirements, which we reported on here.
See "SEC Commissioner Hester Pierce's Coherent and Persuasive Deconstruction of the Proposed SEC ESG Disclosure Rulemaking " (ProfessorBainbridge.com), “SEC Commissioner warns of partisan input from ESG players on potentially ‘lucrative’ disclosure rules” (Responsible Investor), "SEC commissioner voices concern over potential ESG disclosure rule" (P&I), and our recent reports: “SEC’s AMAC Concludes Mandated ESG Disclosure is Premature,” “Analysis of Climate Disclosure Comment Letters,” and “Society Submits Climate Disclosure Comment Letter.”
This post first appeared in the weekly Society Alert!