12 June 2021
COMMENTS OF THE CENTER FOR CLIMATE AND ENERGY SOLUTIONS This document constitutes the comments of the Center for Climate and Energy Solutions (C2ES) on the request for input to guide the Securities and Exchange Commission (SEC) on climate-related financial disclosures. [...] The specifics of disclosure requirements should be phased in over time to reflect current availability of data and reporting standards and to allow for the development of new reporting standards or guidance; the SEC should lead a pre-determined stakeholder Center for Climate and Energy Solutions 2 engagement process to regularly convene both investors and companies as best practice emerges. [...] To that end, the SEC should immediately assess where and how to guide the use and disclosure of scenario analysis, and survey stakeholders about the utility of mandating specific scenarios by sector, including where flexibility is best provided, with input from registrants and investors. [...] How should disclosures under any such standards be enforced or assessed? For example, what are the advantages and disadvantages of making disclosures subject to audit or another form of assurance? Auditing and other forms of assurance are important to ensure that climate-related information is correct and to support the mainstreaming of decision-useful, standardized emissions data and information. [...] Sub-question 13.1: What are the advantages and disadvantages of requiring disclosed metrics to be accompanied with a sustainability disclosure and analysis section similar to the current Management’s Discussion and Analysis of Financial Condition and Results of Operations? As a general goal, the SEC should seek to identify a consistent, meaningful, and comparable disclosure format and disclosure l.