Summary of the R Street Institute

In response to the Commission’s (SEC) request for comment on its proposed rule “The Enhancement and Standardization of Climate-Related Disclosures for Investors,” this document aims to answer several questions offered in the proposal. This response is not an exhaustive response to the Commission’s proposed rule, but instead represents a response to key components of the proposal that we feel are detrimental to both market and environmental outcomes. This response should be viewed neither as endorsement nor condemnation of the Commission’s proposed rule.

The R Street Institute (RSI) is a free market-oriented think tank focusing on market-based solutions to public policy problems. RSI believes in and affirms that strong capacity of private enterprise and freedom of expression through consumer choice are invaluable tools in addressing many public challenges, allowing society to achieve the best outcomes at the least cost. RSI was founded as a direct counterpoint to those who dismissed climate change, and as an institution has aimed to identify and educate on opportunities for market-based policy to address climate change. The Commission’s proposed rule creates an opportunity to enhance market function by furnishing investors with better information regarding their exposure to climate-related risk, and an appropriate standardization of definitions for firms that claim to be offsetting or negating climate-related risk. However, in several aspects, we note that the proposed rule would interfere with markets, obfuscate material information to investors as to climate-related risk and worsen private-sector led emission mitigation efforts.

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