SEC consultation response
24 Jun 2022
We believe it is important that institutional investors and asset owners take a lead role in understanding, quantifying and reporting on the risks and opportunities presented by climate change, so that they can make better informed investment decisions on behalf of beneficiaries. Given the importance of US markets to our clients, we recently respond to the Securities and Exchange Commission (SEC) consultation on a proposed Rule on Climate Related Disclosures.
The availability of consistently reported data is critical to improving decision making and we were therefore pleased to support this proposal. However, we believe that the SEC can go further in better aligning the Rule with the TCFD framework, ensuring that Scope 3 emissions are reported where material and ensuing that the Rule is sufficiently flexible to adapt to changing market practices and expectations.
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