June 10, 2021

Vanessa Countryman
Secretary
Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549-1090

Re: Public Input on Climate Change Disclosures

Dear Ms. Countryman,

The Securities Industry and Financial Markets Association (“SIFMA”)1 appreciates the opportunity to share our perspectives on the issues we believe are important for the Securities and Exchange Commission (the “SEC” or “Commission”) to consider as it evaluates creating climate change-related disclosure rules in response to Commissioner Lee’s March 15, 2021 statement requesting public input on climate change disclosures (the “Request”).2

In light of the preliminary nature of the Request, our comments are high-level and represent SIFMA’s initial thinking on the delineated topics.3 SIFMA remains available to assist the SEC as it moves towards proposed rules and will provide additional comments in response to any such proposal. SIFMA urges the SEC to take action on climate disclosure through formal rulemaking, thus allowing for appropriate public notice and comment periods to opine on the proposals.

In an effort to avoid duplication and repetition, we address the main thematic points that will facilitate the disclosure by registrants of quality, usable information on climate change. Many of these recommendations respond to more than one of the questions presented in the Request, which we have noted below. We welcome the opportunity to meet with the SEC staff at its convenience to further discuss our recommendations.

SIFMA welcomes the SEC’s involvement in facilitating the disclosure of consistent, clear, intelligible, comparable and accurate information on climate change that is useful to investors. Creating enduring rules that meet investor needs but that are not unduly burdensome on registrants will require close coordination between the SEC and multiple domestic and international regulatory bodies and authorities and other stakeholders, as well as a careful balancing of potentially competing priorities. The SEC and the United States should take an active leadership role in the ongoing international work to facilitate global consistency and pragmatism in climate-related disclosure rules and guidelines.4

1 SIFMA is the voice of the U.S. securities industry. We represent the broker-dealers, banks and asset managers whose nearly 1 million employees provide access to the capital markets, raising over $2.5 trillion for businesses and municipalities in the U.S., serving clients with over $18.5 trillion in assets and managing more than $67 trillion in assets for individual and institutional clients including mutual funds and retirement plans. SIFMA, with offices in New York and Washington, D.C., is the U.S. regional member of the Global Financial Markets Association (GFMA).
2 See Then-Acting Chair Allison Herren Lee, Public Input Welcomed on Climate Change Disclosures, U.S. SECURITIES AND EXCHANGE COMMISSION (March 15, 2021), https://www.sec.gov/news/public-statement/lee-climate-change-disclosures.
3 This letter is being submitted on behalf of SIFMA’s broker-dealer and investment bank members. SIFMA’s Asset Management Group is submitting a separate response. SIFMA appreciates the assistance of Michael Littenberg, Alexander Simkin, and Dominique Rioux of Ropes & Gray LLP in the preparation of this response.