The U.S. Chamber of Commerce (“Chamber”) writes to further supplement our comments on the proposed rules (the “Proposed Rules”) of the Securities and Exchange Commission (“SEC or “Commission”) governing climate and the environment in Release No. 33-11042 (the “Proposing Release”). Since the Chamber’s initial comment letter to the SEC on June 16, 2022, there have been noteworthy updates to the SEC’s comment file and the broader climate disclosure landscape that merit discussion.

As Chamber Senior Vice President David Hirschmann noted in introductory remarks during Chair Gary Gensler’s appearance at the Chamber on October 26, 2023 (“Chamber event”) , policymakers across the globe – from California to the European Union and Singapore – are moving to implement mandatory reporting requirements on climate-related information. The risk of resulting fragmentation makes it all the more important that the SEC proceed with great care.