Date: February 10, 2017

Issue: Corporate Disclosure

To: Financial Stability Board (FSB), Bank for International Settlements

Filing Type: Comment Letter

Description: CCMC is concerned with the FSB's report, Recommendations of the Task Force on Climate-Related Financial Disclosures, which asserts, on page 35 and elsewhere, that companies should be required to provide climate-related disclosures in their “mainstream (i.e., public) financial filings” because doing so “will ensure that appropriate controls govern the production and disclosure of the required information.” This is not, and has never been, the standard for disclosure under the federal securities laws. No matter the topic or the merit of any proposed disclosure’s objective, the Supreme Court’s traditional materiality standard should be the benchmark as the SEC, and other policymakers in the U.S. consider whether to impose new disclosure obligations on reporting companies.

Download PDF