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Agency FilingFinancial DisclosureFinancial Regulation

Comments to the CFTC on Climate-Related Financial Risk (Sabin Center)

These comments strongly support the Commodity Futures Trading Commission's ("Commission") efforts to respond to the financial consequences of climate change and highlight the legal basis for appropriate rule-making to address these risks. Regulations to address climate risk are consistent with the Commission's mandate to ensure the integrity of transactions under…
Eleonor Dyan Garcia, Cynthia Hanawalt and Romany Webb
October 7, 2022
Agency FilingEnergy RegulationFederal Energy Regulation

Comments to FERC on One-Time Informational Reports on Extreme Weather Vulnerability Assessments

In these comments, EDF and the Sabin Center support the Commission’s proposal to require transmission providers to file one-time informational reports describing their current or planned policies and processes for conducting extreme weather vulnerability assessments. In promulgating a final rule, EDF and the Sabin Center recommend that the Commission supplement…
Ted Kelly, Noha Haggag, Michael Panfil, Nicole Buell, Natalie Karas, Jason Gray and Romany Webb
August 30, 2022
Agency FilingFinancial DisclosureFinancial Regulation

Comments to the SEC on Fund ESG Disclosures (Policy Integrity)

The SEC has proposed a series of new disclosures for investment companies regarding their Environmental, Social, and Governance (ESG) activities. These disclosures would reduce "greenwashing" - a practice where companies misrepresent the sustainability of their investments in order to advertise to investors looking to invest in green funds - by…
Jack Lienke and Bridget Pals
August 16, 2022
Agency FilingFinancial DisclosureFinancial Regulation

Comments to the ISSB on Climate-Related Disclosures Exposure Draft

These comments support the Climate-Related Disclosures Exposure Draft of the International Sustainability Standards Board (ISSB), which will provide investors around the globe with the information necessary to inform their investment decisions. The comments commend the ISSB’s goal of creating a global baseline and encourage the ISSB to consider certain modifications…
Noha Haggag, Stephanie Jones, Michael Panfil, Andrew Howell and Jake Hiller
July 29, 2022
Agency FilingFinancial DisclosureFinancial Regulation

Comments to the SEC from Climate Scientists/Experts on Proposed Rule on Climate-Related Disclosures

These comments from 15 climate scientists and experts discuss the science of climate change detection and attribution—the body of research that helps to characterize the role of human activity in climate change—as well as how models are used to develop climate change projections. The goal of these comments is to…
Michael Burger, Jeffrey Fralick, Radley Horton, Romany Webb and Others
June 17, 2022
Agency FilingFinancial DisclosureFinancial Regulation

Comments to the SEC on Reasoned Explanation for Its Proposed Rule on Climate-Related Disclosures

This letter focuses on two aspects of the justification provided by the Securities and Exchange Commission (SEC) for its proposed rule on climate-related disclosures. First, the letter evaluates the Commission’s rationale for using prescriptive—as opposed to principles-based—disclosure requirements for climate-related financial risk. Second, the letter evaluates the Commission’s rationale for…
Lance Bowman, Jack Lienke, Bridget Pals, Alex Song, Michael Panfil, Noha Haggag, Stephanie Jones, Madison Condon and Others
June 17, 2022
Agency FilingFinancial DisclosureFinancial Regulation

Comments to the SEC on Economic Analysis for Its Proposed Rule on Climate-Related Disclosures

In response to the Securities and Exchange Commission's proposed rule on climate-related disclosures, this letter commends the SEC for conducting an economic analysis that is consistent with relevant case law, and suggests some revisions that would provide additional context and support for the final analysis.
Lance Bowman, Jack Lienke, Bridget Pals, Alex Song, Michael Panfil, Noha Haggag, Stephanie Jones and Madison Condon
June 17, 2022