Response or Comment
The Center for International Environmental Law, Center of Concern, Environmental Investigation Agency-US, Foundation Earth, Friends of the Earth-United States, Greenpeace USA, Rainforest Action Network, and the Sierra Club welcome the opportunity to comment on the recent Securities and Exchange Commission (“SEC”) concept release on “Business and Financial Disclosure Required by Regulation S-K” (“Concept Release”).1In this Comment Letter, we address five issues:(1) the growth of socially-responsible investment (SRI)(Concept Release questions 15, 17); (2) the definition of materiality (question6); (3) the materiality of sustainability information (questions216-23); and (4) the limits of voluntary disclosure initiatives to meet the information needs of today’s investors, both SRI investors and non-SRI (questions205-15, 216-18, 223). We also ask the SEC to issue mandatory sustainability disclosure regulations and offer preliminary suggestions on the main aspects that sustainability disclosure regulations would have to cover in order to inform investment decisions while effectively addressing environmental, social, and governance concerns (questions21, 23, 219).
Williams, Cynthia, "Comment Letter to the SEC in response to its Concept Release on Business and Financial Disclosure Required by Regulation S-K, 81 F.R. 23915" (2016). Commissioned Reports, Studies and Public Policy Documents. Paper 209.