CFA Institute supports the spirit of the Proposed Rule. Investors want more information on climate-related risks and opportunities for value-relevant investment decision making. We know from 60-plus years of advocating on behalf of investors that what gets disclosed gets monitored, measured, and managed—not only by investors but also by management. This Proposal rightly brings climate-related risks into the sphere of improved information for investment decision making, the perspective from which we respond to the Proposal.

The Executive Summary provides a bullet point summation of our views on the 200+ questions in the Proposal. Several overarching or cross-cutting issues emerged as we reviewed the Proposal, which we address in the Overarching Considerations section. We note that we believe additional industry-based disclosures consistent with the SASB, soon to be ISSB, standards are needed to make the disclosures the SEC is proposing, both outside and inside the financial statements, most decision-useful for investors.