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15Rock's Open Comments to SEC's Proposed Rule Requiring Publicly Traded Firms to Disclose Climate-Related Financial Risk Information (S7-10-22)

15Rock express supports SEC to disclose climate-related financial risk information (S7-10-22).

I am writing on behalf of 15Rock to express our strong support for the Securities and Exchange Commission's (SEC) proposed rule requiring publicly traded firms to disclose climate-related financial risk information (S7-10-22). Every aspect of the U.S. and global economy, including energy production, infrastructure, agriculture, residential and commercial real estate, product supply chains, human health, and labor productivity, is already being impacted by climate change. Climate change poses significant risks to companies and their investors, including physical risks to real assets as a result of the increasing frequency and severity of extreme weather events. There are transition risks posed by changes in regulation, technology, and market preferences as we transition to a net-zero economy.

After such disclosures, we believe the SEC should focus on climate governance and examine transition reporting expeditiously - meaningful plans to provide credibility to NetZero for investors to have enough information to make decisions factoring in climate. There is a considerable risk of public distrust as a result of the fact that many corporations make claims without demonstrating their activities, nor are their emissions data linked with their pledges; this can have adverse effects on their stock prices. We believe that these pledges are material and must be treated as such.  If we do not make an immediate adjustment, climate change will disrupt our way of life.

Investors require comprehensive and meaningful information regarding investment risks associated with climate change. Public trust in capital markets is a foundation of our market’s functioning and the proposal is a step in the right direction but it must be a start with the goal to be focused on actions & transition.

Thank you for proposing this regulation, and 15Rock urges the SEC to swiftly enact the proposed changes.

Gautam Bakshi

Head of Product & Engineering

Former: MD - Private Markets, Wealth & Asset Management, Manulife. Education: Ryerson University, Seneca College

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