Date: July 26, 2013
Issue: Accounting
To: The Sustainability Accounting Standards Board
Filing Type: Regulatory
Description: CCMC believes the SASB’s Conceptual Framework compares favorably to that of IIRC and others in its characterization of the target audience of public company reporting. We agree with the SASB’s recognition that the primary beneficiary and target audience of companies’ reports is the long-term “reasonable investor”, which excludes “specialty focused” shareholders, which pursue non-economic motives through their share ownership.3 In this regard, we believe the SASB should further clarify language throughout the Proposed Framework which suggests that disclosures should be tailored to interests other than the reasonable shareholder.