In May 2026 the SEC proposed to rescind its 2024 climate-related disclosure rules in their entirety (Release Nos. 33-11421; 34-105572, File No. S7-2026-19). Those rules — adopted in March 2024 but stayed by the Commission and never brought into effect — would have required public companies to disclose material climate-related risks and their financial effects, the governance and risk-management processes for those risks, any material climate targets or transition plans, certain Scope 1 and Scope 2 greenhouse-gas emissions, and the effects of severe weather events in a note to the financial statements. The Commission now proposes to withdraw them, on two independent grounds: that the rules exceed its statutory disclosure authority, and that they are unsound as policy — unnecessary alongside the existing materiality-based regime, straying beyond the policy concerns of the federal securities laws, imposing costs not justified by their informational benefit, and working against capital formation. The public has until August 3, 2026 to comment. Read the proposing release (PDF), or browse the SEC’s public comment file.
This tracker was prepared by Tzachi Zach as a public service, in collaboration with Claude — to log the comment letters as they arrive, classify each letter’s position and the rationales it invokes, and surface the patterns in the docket. Because this proposal is a repeal, positions are labelled by what the writer wants done to the rules: Support rescission means repeal them, Oppose rescission means keep them. Position, commenter type and every rationale are coded by a three-reader ensemble; click any letter to see the supporting quote behind each tag.
This project is part of a series, applying the same approach as my trackers for the SEC’s semiannual-reporting proposal (S7-2026-15) and filer-status proposal (S7-2026-18) — both worth a look for context on how these dockets unfold. Comments, suggestions, or corrections welcome.
Sarah McVay helped significantly in building the classification scheme — the rationale taxonomy used here reflects her detailed review of an earlier version.
I also thank Mert Erinc for comments and suggestions.
Further feedback is welcome at zach.7@osu.edu.
11,467 submitters filed the SEC Type A template (or a variant of it). It opposes the rescission — it urges the SEC to keep the 2024 climate-disclosure rules. Held separate from the 89 individual letters and never summed into the stance counts (the campaign total is anonymous and may overlap with named letters).
Rationale tags: IP CMP CFR ENV DEMAND FRAG
2,348 submitters filed the SEC Type B template (or a variant of it). It opposes the rescission — it urges the SEC to keep the 2024 climate-disclosure rules. Held separate from the 89 individual letters and never summed into the stance counts (the campaign total is anonymous and may overlap with named letters).
Rationale tags: IP CFR ENV
| # | Date | Name | Position | Entity | Rationales |
|---|---|---|---|---|---|
| ▾ July 24, 2026 1 letter | |||||
| ▸83 | July 24, 2026 | Sadie Schwefel | Oppose rescission | Individual | CFR |
Position: Oppose rescission (split) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework CFR Climate-related financial risk — “Climate risk is financial risk.” | |||||
| ▾ July 23, 2026 4 letters | |||||
| ▸87 | July 23, 2026 | Mika Weinstein, Chief Executive Officer, Just Futures | Oppose rescission | Investor / asset manager (institutional) | CFR CMP FRAG IP |
Position: Oppose rescission (unanimous) · Entity: Investor / asset manager (institutional) (unanimous) Modification posture: No modification requested — no substantive request to change the framework CFR Climate-related financial risk — “which has treated climate as a balance-sheet variable for years” CMP Standardization / comparability — “Recission takes a standardized, audited baseline any investor could use and turns it back into something only the largest firms can afford to rebuild on their own.” FRAG Regulatory fragmentation / multi-jurisdictional consistency — “Most large US companies worth investing in already report climate data to both the European Union and California which require it.” IP Investor protection / decision usefulness — “We owe our clients a fiduciary duty, and because their horizons run in decades, so do ours” | |||||
| ▸86 | July 23, 2026 | Mathew Jensen CFA, Senior Investment Officer, UUA Investment Office | Oppose rescission | Investor / asset manager (institutional) | Fallback / Compromise ACCT AUTH CAPFORM CB CBA CFR CMP DEMAND FRAG INSUFF IP WHIP GHG12 GOV FINSTMT TARGETS |
Position: Oppose rescission (unanimous) · Entity: Investor / asset manager (institutional) (unanimous) Modification posture: Fallback / Compromise — primary position is clear; a second-best alternative is offered if it is rejected Keep provisions: GHG12 (Scope 1 & 2 emissions), GOV (Governance / risk management), FINSTMT (Financial-statement effects (Reg S-X Art. 14)), TARGETS (Targets / transition plan) ACCT Stewardship / accountability — “The governance and risk-oversight disclosures — board oversight and management's role in assessing and managing climate-related risk — as discrete, structured Item 103/105-style requirements rather than unstructured MD&A discussion” AUTH Statutory authority / major-questions (either direction) — “fall comfortably within the Commission's traditional, well-established disclosure authority” CAPFORM Market efficiency / capital formation — “A single, well-calibrated federal disclosure standard would give issuers one clear, cost-effective baseline usable across these regimes” CB Compliance burden — “Those costs are substantially mitigated when issuers have a clear disclosure framework to follow, which increases certainty around disclosure obligations and reduces compliance risk.” CBA Cost-benefit assessment — “The rescission Proposal's cost-benefit analysis emphasizes the compliance costs registrants would avoid, but that analysis is misleading.” CFR Climate-related financial risk — “UUCEF and its external investment managers routinely encounter climate-related risks that bear directly on a corporation's cost of capital, asset values, insurance availability, and long-term earnings power” CMP Standardization / comparability — “standardized, mandatory, comparable climate disclosure is decision-useful” DEMAND Investor demand / fund reliance — “In an October 2022 analysis of comments from 320 institutional investors, Ceres found that 97% supported requiring the Rules' disclosures in Form 10-K.” FRAG Regulatory fragmentation / multi-jurisdictional consistency — “Many companies held in UUCEF portfolios are already subject to overlapping climate-reporting obligations under California's SB 253 and SB 261, the EU's Corporate Sustainability Reporting Directive and European Sustainability Reporting Standards, and the International Sustainability Standards Board-aligned S2 disclosure regimes” INSUFF Insufficient / incoherent legal basis (either direction) — “The Commission's rationale for rescission is deficient and does not justify full rescission.” IP Investor protection / decision usefulness — “Climate-related financial information is a routine input into UUCEF's investment oversight, manager monitoring, stewardship, valuation, and risk-management processes across public and private portfolios.” WHIP Regulatory whiplash / reliance interests / costs already incurred — “not through wholesale rescission of a rule for which the investor community spent years building a supportive record” | |||||
| ▸85 | July 23, 2026 | Katie Carter, Director of Faith-Based Investing and Shareholder Engagement, Presbyterian Church U.S.A. | Oppose rescission | Investor / asset manager (institutional) | ACCT AUTH CB CFR CMP DEMAND FRAG IP |
Position: Oppose rescission (unanimous) · Entity: Investor / asset manager (institutional) (unanimous) Modification posture: No modification requested — no substantive request to change the framework ACCT Stewardship / accountability — “we engage as shareholders with hundreds of corporations on their environmental and social impacts, and on strong governance practices.” AUTH Statutory authority / major-questions (either direction) — “we respectfully disagree with this Commission's unprecedented and illogical argument that it somehow lacks the authority to do what Congress charged it to do.” CB Compliance burden — “the Rules are not unduly burdensome to companies, as they require disclosure only of information that applies to a particular company's operations” CFR Climate-related financial risk — “We are therefore deeply aware of the long-term consequences to companies associated with climate risk.” CMP Standardization / comparability — “comparable, consistent, and reliable information from issuers” DEMAND Investor demand / fund reliance — “Investors overwhelmingly supported the SEC's 2025 Climate Disclosure Rules.” FRAG Regulatory fragmentation / multi-jurisdictional consistency — “including mandatory disclosures for companies doing business in California and the E.U., as well as voluntary sets of reporting standards such as ISSB and GRI.” IP Investor protection / decision usefulness — “would provide investors with decision-useful financial information” | |||||
| ▸84 | July 23, 2026 | James A Frazin, CFP, AIF, CEO, Communitas Financial Planning PBC | Oppose rescission | Investor / asset manager (institutional) | ACCT AUTH CAPFORM CFR CMP DEMAND ENV INSUFF IP |
Position: Oppose rescission (unanimous) · Entity: Investor / asset manager (institutional) (unanimous) Modification posture: No modification requested — no substantive request to change the framework ACCT Stewardship / accountability — “Rescinding this requirement removes a powerful, standardized mechanism that forces corporate boards to actively manage, mitigate, and answer for long-term, high-consequence physical and transition risks.” AUTH Statutory authority / major-questions (either direction) — “By arguing that SEC mandates must strictly adhere to Schedule A of the 1933 Securities Act, the Commission has created a litigation pathway to strike down other essential modern disclosure rules.” CAPFORM Market efficiency / capital formation — “creating systemic market inefficiencies, and weakening corporate governance in U.S. capital markets.” CFR Climate-related financial risk — “systemic climate risks, such as supply chain disruptions from extreme weather, transition risks, and regulatory compliance costs, deeply impact long-term corporate valuation.” CMP Standardization / comparability — “Investors Need Standardized, Comparable Data” DEMAND Investor demand / fund reliance — “Investors have been calling for increased disclosure and regulation around climate-related risks for decades because they recognize the impact these factors have on their financial returns.” ENV Environmental impact / consequences — “the present value of social costs generated by US companies' future GHG emissions at $87 trillion” INSUFF Insufficient / incoherent legal basis (either direction) — “the Commission discards decades of judicial precedent, including the landmark TSC Industries "total mix" standard, which explicitly recognizes that qualitative factors are vital to the information a reasonable investor relies upon to make informed decisions.” IP Investor protection / decision usefulness — “The proposed rescission represents a significant step backward for market transparency by denying investors access to standardized, comparable data.” | |||||
| ▾ July 22, 2026 1 letter | |||||
| ▸88 | July 22, 2026 | Elizabeth Steiner, MD, Oregon State Treasurer, Oregon State Treasury | Oppose rescission | Government / elected official | Fallback / Compromise CAPFORM CBA CFR CMP DEMAND FRAG INSUFF IP WHIP |
Position: Oppose rescission (unanimous) · Entity: Government / elected official (unanimous) Modification posture: Fallback / Compromise — primary position is clear; a second-best alternative is offered if it is rejected CAPFORM Market efficiency / capital formation — “the competitiveness of U.S. markets depends on meeting that movement, not retreating from it.” CBA Cost-benefit assessment — “The release monetizes every dollar the commission believes could be saved ($4.9 billion a year, by its own estimate), while recording the costs to investors as "Not Monetized."” CFR Climate-related financial risk — “Climate-related financial risk sits in our portfolio whether or not companies disclose it.” CMP Standardization / comparability — “Uniform disclosure remains the only way to get reliable information across a broad portfolio, and that information is how we manage the risk on behalf of our beneficiaries.” DEMAND Investor demand / fund reliance — “Investors asked for these rules, built the record that supports them, and stepped up to defend them when the Commission would not.” FRAG Regulatory fragmentation / multi-jurisdictional consistency — “roughly three dozen jurisdictions representing about 60 percent of the global economy have adopted or are finalizing requirements aligned with the ISSB standards” INSUFF Insufficient / incoherent legal basis (either direction) — “An agency that built one of the most extensive rulemaking records in its modern history should not set that record aside on a change in policy preference.” IP Investor protection / decision usefulness — “it would help investors assess and correctly price risk” WHIP Regulatory whiplash / reliance interests / costs already incurred — “That statutory program was built on the reasonable expectation that standardized, issuer-reported data was coming.” | |||||
| ▾ July 20, 2026 1 letter | |||||
| ▸82 | July 20, 2026 | S.E.W. | Oppose rescission | Individual | ACCT AUTH CAPFORM CBA CFR CMP DEMAND INSUFF IP PP |
Position: Oppose rescission (unanimous) · Entity: Individual (majority) Modification posture: No modification requested — no substantive request to change the framework ACCT Stewardship / accountability — “hold companies accountable for their environmental impacts” AUTH Statutory authority / major-questions (either direction) — “Congress granted the SEC the authority to require corporate disclosure to inform investors about financial risk” CAPFORM Market efficiency / capital formation — “facilitate capital formation” CBA Cost-benefit assessment — “Imposes costs not justified by benefits” CFR Climate-related financial risk — “companies disclose climate risks related to company activities, assets, and products” CMP Standardization / comparability — “Investors have long sought consistent and comparable climate risk disclosure” DEMAND Investor demand / fund reliance — “Investors have been seeking corporate disclosure of material climate risks since 2003” INSUFF Insufficient / incoherent legal basis (either direction) — “The rationale for rescinding the rule misinterprets both history and law” IP Investor protection / decision usefulness — “investors can not make informed decisions about where and how to invest their resources” PP Political pressure / regulatory capture — “the SEC is responding not to what voters and investors want, but to what donors and powerful corporate interests want” | |||||
| ▾ July 19, 2026 1 letter | |||||
| ▸89 | July 19, 2026 | Sr. Marcelline Koch, OP, Dominican Sisters of Springfield, Illinois | Oppose rescission | Investor / asset manager (institutional) | Fallback / Compromise ACCT CAPFORM CBA CFR CMP ENV FRAG IP WHIP |
Position: Oppose rescission (unanimous) · Entity: Investor / asset manager (institutional) (unanimous) Modification posture: Fallback / Compromise — primary position is clear; a second-best alternative is offered if it is rejected ACCT Stewardship / accountability — “help us and our investment advisers assess company strategy, board oversight, financial exposure, and the credibility of climate commitments” CAPFORM Market efficiency / capital formation — “A common framework can reduce duplicative requests and improve capital allocation.” CBA Cost-benefit assessment — “The costs of disclosure should also be weighed against the costs to investors and markets when information is incomplete or inconsistent.” CFR Climate-related financial risk — “Climate-related physical and transition risks can affect operations, costs, asset values, business models, and long-term competitiveness.” CMP Standardization / comparability — “Standardized disclosure is necessary because voluntary climate reporting remains uneven.” ENV Environmental impact / consequences — “Our mission calls us to promote justice, care for creation, and consider how economic activity affects people who are poor or marginalized.” FRAG Regulatory fragmentation / multi-jurisdictional consistency — “It would also increase fragmentation as other jurisdictions continue to develop reporting requirements.” IP Investor protection / decision usefulness — “As long-term investors, we rely on company disclosures to assess whether boards and management are addressing financially material risks.” WHIP Regulatory whiplash / reliance interests / costs already incurred — “Rescission would create regulatory uncertainty after investors and companies have spent years preparing for more consistent climate disclosure.” | |||||
| ▾ July 17, 2026 2 letters | |||||
| ▸81 | July 17, 2026 | Anonymous | Oppose rescission | Individual | ACCT |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework ACCT Stewardship / accountability — “an important part of good corporate governance” | |||||
| ▸80 | July 17, 2026 | Ed McCauley, Retired Auditor | Support rescission | Individual | CB IMMAT |
Position: Support rescission (unanimous) · Entity: Individual (majority) Modification posture: No modification requested — no substantive request to change the framework CB Compliance burden — “spend time and money on disclosures that deal with climate change” IMMAT Immaterial / not decision-useful — “We do not control the climate” | |||||
| ▾ July 16, 2026 1 letter | |||||
| ▸79 | July 16, 2026 | David Bauer | Oppose rescission | Individual | Fallback / Compromise AUTH CBA CFR ENV IP |
Position: Oppose rescission (majority) · Entity: Individual (unanimous) Modification posture: Fallback / Compromise — primary position is clear; a second-best alternative is offered if it is rejected AUTH Statutory authority / major-questions (either direction) CBA Cost-benefit assessment — “are not justified by the informational benefits they may provide to some investors” CFR Climate-related financial risk — “Examples of how these changes affect people and companies are plentiful.” ENV Environmental impact / consequences — “That the climate is changing is observed, settled science.” IP Investor protection / decision usefulness — “The purpose and features of said laws include protecting investors from hidden risks” | |||||
| ▾ July 15, 2026 2 letters | |||||
| ▸78 | July 15, 2026 | Randi Val Morrison, General Counsel and Chief Knowledge Officer, Society for Corporate Governance and Paul F. Washington, President and Chief Executive Officer, Society for Corporate Governance | Support rescission | Business trade association / advocacy org | Modify / Improve or Clarify CB CBA FRAG IMMAT INSUFF REDUN |
Position: Support rescission (unanimous) · Entity: Business trade association / advocacy org (unanimous) Modification posture: Modify / Improve or Clarify — asks for a revised, clarified or better-designed framework CB Compliance burden — “prior comment letters discussed the significant costs and implementation challenges” CBA Cost-benefit assessment — “evaluation of the costs and benefits of the Rules.” FRAG Regulatory fragmentation / multi-jurisdictional consistency — “the increasingly fragmented disclosure environment in which registrants operate” IMMAT Immaterial / not decision-useful — “numerous climate-related metrics, governance structures, and processes irrespective of whether the” INSUFF Insufficient / incoherent legal basis (either direction) REDUN Redundant — existing rules, materiality regime, or voluntary reporting already suffice — “material to investors and that additional prescriptive climate disclosure mandates are unnecessary.” | |||||
| ▸77 | July 15, 2026 | Jonas Kron, Esq., Chief Advocacy Officer, Trillium Asset Management, LLC | Oppose rescission | Investor / asset manager (institutional) | CAPFORM CB CBA CFR CMP DEMAND FRAG INSUFF IP |
Position: Oppose rescission (unanimous) · Entity: Investor / asset manager (institutional) (unanimous) Modification posture: No modification requested — no substantive request to change the framework CAPFORM Market efficiency / capital formation — “pricing, allows us to allocate capital more effectively.” CB Compliance burden — “balance between the investment of time and effort needed to prepare disclosures and the value” CBA Cost-benefit assessment — “we believe the Rules, as written, strike a fair” CFR Climate-related financial risk — “acute physical climate risks, provide visibility into new or enhanced business opportunities that” CMP Standardization / comparability — “investors may more easily compare climate-related data between” DEMAND Investor demand / fund reliance — “Climate-related analysis and risk assessment are also a key part of Trillium” FRAG Regulatory fragmentation / multi-jurisdictional consistency — “being asked to report according to overlapping disclosure regimes.” INSUFF Insufficient / incoherent legal basis (either direction) IP Investor protection / decision usefulness — “portfolio managers can view ESG metrics including carbon intensity” | |||||
| ▾ July 13, 2026 2 letters | |||||
| ▸76 | July 13, 2026 | Marc | Oppose rescission | Individual | NR |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework NR No substantive rationale | |||||
| ▸75 | July 13, 2026 | Cory L. Andrews, General Counsel, and Jerome P. DeSanto, Jr., Washington Legal Foundation | Support rescission | Legal practitioner | 1A AUTH CAPFORM CB CBA IMMAT INSUFF REDUN |
Position: Support rescission (unanimous) · Entity: Legal practitioner (unanimous) Modification posture: No modification requested — no substantive request to change the framework 1A Compelled speech / First Amendment (either direction) — “SPEECH IN VIOLATION OF THE FIRST AMENDMENT.” AUTH Statutory authority / major-questions (either direction) — “recognizes that the rules exceed its statutory authority.” CAPFORM Market efficiency / capital formation — “WLF supports regulatory reforms that promote effective” CB Compliance burden — “to make burdensome disclosures on greenhouse gas emissions” CBA Cost-benefit assessment — “At best, any asserted benefits of the disclosure rules are highly uncertain,” IMMAT Immaterial / not decision-useful — “present or future financial condition is inherently speculative and unreliable.” INSUFF Insufficient / incoherent legal basis (either direction) REDUN Redundant — existing rules, materiality regime, or voluntary reporting already suffice — “disclose material risks to their businesses regardless of source.” | |||||
| ▾ July 12, 2026 2 letters | |||||
| ▸74 | July 12, 2026 | John Kuriawa | Oppose rescission | Individual | Fallback / Compromise ACCT CFR INSUFF IP |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: Fallback / Compromise — primary position is clear; a second-best alternative is offered if it is rejected ACCT Stewardship / accountability — “help reduce potential future liabilities, greenwashing, and the social costs” CFR Climate-related financial risk — “Climate risks and opportunities are clearly material to large corporations and their investors” INSUFF Insufficient / incoherent legal basis (either direction) IP Investor protection / decision usefulness — “Such a change will decrease transparency and critical information investors need to make informed decisions.” | |||||
| ▸73 | July 12, 2026 | Shiva Rajgopal, Columbia Business School | Oppose rescission | Academic researcher | Fallback / Compromise ACCT AUTH CAPFORM CB CBA CFR CMP DEMAND FRAG INSUFF IP WHIP FINSTMT GHG12 GOV |
Position: Oppose rescission (unanimous) · Entity: Academic researcher (unanimous) Modification posture: Fallback / Compromise — primary position is clear; a second-best alternative is offered if it is rejected Keep provisions: FINSTMT (Financial-statement effects (Reg S-X Art. 14)), GHG12 (Scope 1 & 2 emissions), GOV (Governance / risk management) ACCT Stewardship / accountability — “Managers may have incentives to disclose favorable climate narratives” AUTH Statutory authority / major-questions (either direction) CAPFORM Market efficiency / capital formation — “They affect risk. They affect capital allocation.” CB Compliance burden — “Initial compliance often requires system design, documentation, remediation, staffing,” CBA Cost-benefit assessment — “That is not a defensible cost-benefit analysis. It is a cost enumeration.” CFR Climate-related financial risk — “climate-related risk affects conventional financial variables: revenue, input costs, asset lives,” CMP Standardization / comparability — “Comparability is itself an economic benefit.” DEMAND Investor demand / fund reliance — “investor demand, under state law, under international regimes” FRAG Regulatory fragmentation / multi-jurisdictional consistency — “Many U.S. registrants also face international sustainability disclosure obligations, including European” INSUFF Insufficient / incoherent legal basis (either direction) IP Investor protection / decision usefulness — “into valuation, risk assessment, stewardship, portfolio construction, and credit analysis.” WHIP Regulatory whiplash / reliance interests / costs already incurred — “recognize disclosure systems already built by large” | |||||
| ▾ July 11, 2026 1 letter | |||||
| ▸72 | July 11, 2026 | Victoria Novitch | Oppose rescission | Individual | ACCT CB CBA ENV |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework ACCT Stewardship / accountability — “This keeps them accountable.” CB Compliance burden — “These companies make millions, and they CAN afford it.” CBA Cost-benefit assessment — “costs the Medicare system more than the most expensive reporting fee listed” ENV Environmental impact / consequences — “The people of this country deserve full transparency when it comes to the quality of the air we breathe.” | |||||
| ▾ July 8, 2026 1 letter | |||||
| ▸71 | July 8, 2026 | Anonymous | Oppose rescission | Individual | ENV |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework ENV Environmental impact / consequences — “there will be no more investors or public companies if they cannot survive in the world that we chose to monetize” | |||||
| ▾ July 6, 2026 3 letters | |||||
| ▸70 | July 6, 2026 | John Corke | Oppose rescission | Individual | NR |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework NR No substantive rationale | |||||
| ▸69 | July 6, 2026 | D. Bishop | Off-topic | Individual | ACCT |
Position: Off-topic (unanimous) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework ACCT Stewardship / accountability — “The corruption happening with in this system is being unmasked and the system is trying so hard to find another way to hide it.” | |||||
| ▸68 | July 6, 2026 | Kayla, Project Manager, Energy Sector | Oppose rescission | Individual | IP |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework IP Investor protection / decision usefulness — “Investors and the general public have the right to the best and most accurate information when making a decision about the financial and moral integrity of an organization” | |||||
| ▾ July 5, 2026 4 letters | |||||
| ▸67 | July 5, 2026 | Kristin Hull, Nia Impact Capital | Oppose rescission | Investor / asset manager (institutional) | Fallback / Compromise CAPFORM CB CFR CMP DEMAND FRAG INSUFF IP WHIP |
Position: Oppose rescission (unanimous) · Entity: Investor / asset manager (institutional) (unanimous) Modification posture: Fallback / Compromise — primary position is clear; a second-best alternative is offered if it is rejected CAPFORM Market efficiency / capital formation — “only ensures the risk is mispriced.” CB Compliance burden — “Rescission does not eliminate disclosure costs” CFR Climate-related financial risk — “Climate risk is financial risk, and material risk belongs in securities filings.” CMP Standardization / comparability — “minimum inputs a diligent analyst needs to compare companies within a sector.” DEMAND Investor demand / fund reliance — “investors asked for this rule.” FRAG Regulatory fragmentation / multi-jurisdictional consistency — “does not deregulate; it fragments.” INSUFF Insufficient / incoherent legal basis (either direction) IP Investor protection / decision usefulness — “would withhold decision-useful information from investors” WHIP Regulatory whiplash / reliance interests / costs already incurred — “for issuers who have already built compliance systems in reliance on the 2024 rule” | |||||
| ▸66 | July 5, 2026 | April Rafael-Adams | Oppose rescission | Individual | ENV IP |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework ENV Environmental impact / consequences — “I like to know what they are doing to protect the environment and my family” IP Investor protection / decision usefulness — “Without this information I would choose someone else to invest in or spend money on.” | |||||
| ▸65 | July 5, 2026 | Anonymous | Oppose rescission | Individual | ENV IP |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework ENV Environmental impact / consequences — “what those businesses are doing to mitigate harms their business practices may incur on our environment” IP Investor protection / decision usefulness — “Reducing investor information is never going to lead to a more informed” | |||||
| ▸64 | July 5, 2026 | Andrew McFain, Ameren | Oppose rescission | Individual | IP |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework IP Investor protection / decision usefulness — “Climate impact is a major factor in my investment decisions.” | |||||
| ▾ July 4, 2026 2 letters | |||||
| ▸63 | July 4, 2026 | Prashant Patel | Oppose rescission | Individual | Modify / Expand ACCT CFR IP |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: Modify / Expand — asks for stronger or broader disclosure ACCT Stewardship / accountability — “if they are not forced to explain their actions nothing will happen” CFR Climate-related financial risk — “Client risk is something businesses need to manage” IP Investor protection / decision usefulness — “as an investor I need to know which company actually have a plan to deal with the risks associated with climate change” | |||||
| ▸62 | July 4, 2026 | Sarah Kimberly Bowen | Oppose rescission | Individual | ENV |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework ENV Environmental impact / consequences — “We should continue to track climate data to track how we can improve the environment protect ourselves from climate change.” | |||||
| ▾ July 3, 2026 2 letters | |||||
| ▸61 | July 3, 2026 | Janet Jacobs | Oppose rescission | Individual | ENV |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework ENV Environmental impact / consequences — “Climate change is a current and future threat to all of us.” | |||||
| ▸60 | July 3, 2026 | Patricia Gunderson | Oppose rescission | Individual | ENV |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework ENV Environmental impact / consequences — “Climate change is a very real source of impact to our health, safety and livelihoods.” | |||||
| ▾ July 2, 2026 2 letters | |||||
| ▸59 | July 2, 2026 | Diane M Basehore | Oppose rescission | Individual | NR |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework NR No substantive rationale | |||||
| ▸58 | July 2, 2026 | Susan Rutan | Oppose rescission | Individual | ENV IP |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework ENV Environmental impact / consequences — “Information about climate impact is vital to the future of the world.” IP Investor protection / decision usefulness — “Investors should be able to use this to evaluate investments.” | |||||
| ▾ July 1, 2026 1 letter | |||||
| ▸57 | July 1, 2026 | Dolores N. Richard | Oppose rescission | Individual | ENV |
Position: Oppose rescission (majority) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework ENV Environmental impact / consequences — “Environmental impact information must be included in all filings.” | |||||
| ▾ June 30, 2026 3 letters | |||||
| ▸56 | June 30, 2026 | Coates, Coffee, Cox, Fox, Lee & Seligman (Shadow SEC Statement No. 10) | Oppose rescission | Academic researcher | Modify / Improve or Clarify ACCT AUTH CAPFORM CB CBA CFR CMP DEMAND FRAG INSUFF IP PP |
Position: Oppose rescission (majority) · Entity: Academic researcher (unanimous) Modification posture: Modify / Improve or Clarify — asks for a revised, clarified or better-designed framework ACCT Stewardship / accountability — “resulting deterrence of greenwashing and other forms of” AUTH Statutory authority / major-questions (either direction) CAPFORM Market efficiency / capital formation — “Improved asset pricing and thus allocation of capital due to better incorporation of” CB Compliance burden — “The gross costs of compliance with the March 2024 rules hardly present a” CBA Cost-benefit assessment — “200 pages of detailed economic analysis, most of which is completely ignored by the” CFR Climate-related financial risk — “risk that energy costs and policy responses by other lawmaking bodies will force” CMP Standardization / comparability — “perpetuates the comparability issues (discussed earlier) among issuers as they compete” DEMAND Investor demand / fund reliance — “they were requested by a wide variety of institutions holding” FRAG Regulatory fragmentation / multi-jurisdictional consistency — “non-US and international standard setters have made to their” INSUFF Insufficient / incoherent legal basis (either direction) IP Investor protection / decision usefulness — “decision-useful for the majority of investors” PP Political pressure / regulatory capture — “conclusory rationalizations for a politically” | |||||
| ▸55 | June 30, 2026 | Katherine Congdon Caldwell | Oppose rescission | Individual | ENV IP PP |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework ENV Environmental impact / consequences — “we are entering a crisis stage with regard to climate change” IP Investor protection / decision usefulness — “It is important for investors to know where companies stand with regard to this issue” PP Political pressure / regulatory capture — “Regardless of the pointed obfuscation by the current Federal government” | |||||
| ▸54 | June 30, 2026 | Brittany Kugler | Oppose rescission | Individual | DEMAND ENV |
Position: Oppose rescission (majority) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework DEMAND Investor demand / fund reliance — “satisfy investor demands for ESG reporting” ENV Environmental impact / consequences — “Businesses should be striving to make less of an environmental impact” | |||||
| ▾ June 29, 2026 1 letter | |||||
| ▸53 | June 29, 2026 | Marilyn Orr | Oppose rescission | Individual | ENV |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework ENV Environmental impact / consequences — “because climate change is happening” | |||||
| ▾ June 28, 2026 1 letter | |||||
| ▸52 | June 28, 2026 | Phillip Goldstein, Managing Partner, Bulldog Investors, LLP | Support rescission | Investor / asset manager (institutional) | IMMAT |
Position: Support rescission (majority) · Entity: Investor / asset manager (institutional) (unanimous) Modification posture: No modification requested — no substantive request to change the framework IMMAT Immaterial / not decision-useful — “so speculative as to be useless in assessing the merits of investing in its securities” | |||||
| ▾ June 27, 2026 1 letter | |||||
| ▸51 | June 27, 2026 | Raymond Shillito | Oppose rescission | Individual | ACCT CFR ENV PP |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework ACCT Stewardship / accountability — “insist that greenwashing is exposed” CFR Climate-related financial risk — “the lack of action on climate change will severely affect investments in a negative way” ENV Environmental impact / consequences — “we are now facing an existential crisis” PP Political pressure / regulatory capture — “the coal and oil interests have used their excessive wealth to delay action for a hundred years” | |||||
| ▾ June 26, 2026 2 letters | |||||
| ▸50 | June 26, 2026 | Daniel Housley, Attorney | Oppose rescission | Legal practitioner | ACCT ENV IP |
Position: Oppose rescission (unanimous) · Entity: Legal practitioner (majority) Modification posture: No modification requested — no substantive request to change the framework ACCT Stewardship / accountability — “promote poor business practices” ENV Environmental impact / consequences — “harms their business practices may incur on our environment and natural climate processes” IP Investor protection / decision usefulness — “Reducing investor information is never going to lead to a more informed” | |||||
| ▸49 | June 26, 2026 | Peter Herrman | Oppose rescission | Individual | CFR IP |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework CFR Climate-related financial risk — “provides data to support whether the company will or won't be profitable in the near future” IP Investor protection / decision usefulness — “is key information to investors” | |||||
| ▾ June 25, 2026 1 letter | |||||
| ▸48 | June 25, 2026 | Marca Hagenstad | Oppose rescission | Individual | CAPFORM CB CBA CFR CMP DEMAND FRAG INSUFF IP |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework CAPFORM Market efficiency / capital formation — “supports the competitiveness of U.S. capital markets” CB Compliance burden — “While implementation requires effort” CBA Cost-benefit assessment — “While implementation requires effort, greater consistency ultimately promotes more efficient capital markets and better-informed investment decisions.” CFR Climate-related financial risk — “affect the financial performance, operations, supply chains, assets, insurance costs, and long-term resilience of many public companies” CMP Standardization / comparability — “helps ensure that material information is reported consistently” DEMAND Investor demand / fund reliance — “lessen the need for companies to respond to numerous differing investor requests” FRAG Regulatory fragmentation / multi-jurisdictional consistency — “reduces unnecessary reporting fragmentation for multinational companies” INSUFF Insufficient / incoherent legal basis (either direction) IP Investor protection / decision usefulness — “provides investors with consistent, comparable, and decision-useful information” | |||||
| ▾ June 24, 2026 1 letter | |||||
| ▸47 | June 24, 2026 | Peter Radford | Oppose rescission | Individual | CFR ENV IP |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework CFR Climate-related financial risk — “or is affected by climate change” ENV Environmental impact / consequences — “how a company affects” IP Investor protection / decision usefulness — “I want to be able to invest with accurate company information” | |||||
| ▾ June 23, 2026 2 letters | |||||
| ▸46 | June 23, 2026 | James H Ross | Oppose rescission | Individual | ENV IP |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework ENV Environmental impact / consequences — “critical for research looking to understand our impact on the world around us” IP Investor protection / decision usefulness — “leverage our financial impact to drive positive change” | |||||
| ▸45 | June 23, 2026 | S Boyd, Chief Strategy Officer of AITrack, Bureau Veritas | Oppose rescission | Issuer / Corporate — current | CFR IP |
Position: Oppose rescission (unanimous) · Entity: Issuer / Corporate — current (majority) Modification posture: No modification requested — no substantive request to change the framework CFR Climate-related financial risk — “Climate-related risk to assets and business strategy has very real financial impact.” IP Investor protection / decision usefulness — “Investors deserve transparency of this financial risk.” | |||||
| ▾ June 22, 2026 1 letter | |||||
| ▸44 | June 22, 2026 | Dena Temple | Oppose rescission | Individual | ACCT ENV |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework ACCT Stewardship / accountability — “helps keep corporations honest” ENV Environmental impact / consequences — “efforts to reduce their effect on our planet” | |||||
| ▾ June 21, 2026 1 letter | |||||
| ▸43 | June 21, 2026 | Richelle Mitchem | Oppose rescission | Individual | CFR IP |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework CFR Climate-related financial risk — “climate-related risks have financial” IP Investor protection / decision usefulness — “investors in public companies consider when making investment and voting” | |||||
| ▾ June 19, 2026 2 letters | |||||
| ▸42 | June 19, 2026 | Anonymous | Oppose rescission | Individual | ACCT CFR ENV IP |
Position: Oppose rescission (majority) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework ACCT Stewardship / accountability — “Every corporation still has an obligation to the communities in which they reside and serve” CFR Climate-related financial risk — “impact the value of their shares when they have to pay for a toxic cleanup” ENV Environmental impact / consequences — “their footprint and environmental impact” IP Investor protection / decision usefulness — “As an investor, I want to know what companies are doing” | |||||
| ▸41 | June 19, 2026 | Emily Stulz | Oppose rescission | Individual | ACCT CB ENV |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework ACCT Stewardship / accountability — “they have to give money BACK to help restore the environments they are destroying” CB Compliance burden — “These companies have more than enough money to submit basic paperwork” ENV Environmental impact / consequences — “they know they are killing the environment” | |||||
| ▾ June 18, 2026 1 letter | |||||
| ▸40 | June 18, 2026 | Melissa Rogers | Oppose rescission | Individual | CFR IP |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework CFR Climate-related financial risk — “including the impact of rising temperatures and rising sea levels on investments” IP Investor protection / decision usefulness — “Investors need all possible information” | |||||
| ▾ June 16, 2026 3 letters | |||||
| ▸39 | June 16, 2026 | Diane Grace | Oppose rescission | Individual | ACCT CFR ENV |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework ACCT Stewardship / accountability — “The cost to restore and remidiate should not be externalized to third parties (consumers, government).” CFR Climate-related financial risk — “should be factored in to the value of a company” ENV Environmental impact / consequences — “Climate impacts from a company's production process” | |||||
| ▸38 | June 16, 2026 | Mary Fujimoto, Citizen | Oppose rescission | Individual | CMP FRAG IP |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework CMP Standardization / comparability — “This rule was a way to standardize reporting across the country.” FRAG Regulatory fragmentation / multi-jurisdictional consistency — “Corporations will still have reporting requirements with many states having different procedures.” IP Investor protection / decision usefulness — “is not a way to help investors and businesses have a standard way to see the climate related impacts on their communities and business” | |||||
| ▸37 | June 16, 2026 | Cheryl Michaels | Oppose rescission | Individual | NR |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework NR No substantive rationale | |||||
| ▾ June 15, 2026 2 letters | |||||
| ▸36 | June 15, 2026 | Dean C Roberts PhD, Management Consultant | Oppose rescission | Individual | CAPFORM CB CBA CFR CMP DEMAND FRAG IP |
Position: Oppose rescission (unanimous) · Entity: Individual (majority) Modification posture: No modification requested — no substantive request to change the framework CAPFORM Market efficiency / capital formation — “reducing information asymmetries and improving market efficiency” CB Compliance burden — “reduces duplicative reporting burdens” CBA Cost-benefit assessment — “eliminating the rule could increase uncertainty and compliance costs rather than reduce them” CFR Climate-related financial risk — “Climate risks increasingly affect asset values, operating costs, supply chains, insurance availability, and long-term competitiveness.” CMP Standardization / comparability — “would reduce the consistency, comparability, and reliability of climate disclosures across public companies” DEMAND Investor demand / fund reliance — “at a time when demand for climate-risk information continues to grow” FRAG Regulatory fragmentation / multi-jurisdictional consistency — “a patchwork of state, international, and private-sector reporting requirements, including those from California, the European Union, lenders, and institutional investors” IP Investor protection / decision usefulness — “Standardized disclosure requirements help ensure that investors receive decision-useful information on a timely and comparable basis” | |||||
| ▸35 | June 15, 2026 | Holly Swiglo | Oppose rescission | Student | CFR IP |
Position: Oppose rescission (unanimous) · Entity: Student (unanimous) Modification posture: No modification requested — no substantive request to change the framework CFR Climate-related financial risk — “Climate change is scientifically proven and undeniably has an impact on the operations of many companies and industries.” IP Investor protection / decision usefulness — “The public should be fully informed about the risks of their investments.” | |||||
| ▾ June 13, 2026 1 letter | |||||
| ▸34 | June 13, 2026 | Mark P Banish | Oppose rescission | Individual | NR |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework NR No substantive rationale | |||||
| ▾ June 11, 2026 3 letters | |||||
| ▸33 | June 11, 2026 | William Jones | Oppose rescission | Individual | ENV |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework ENV Environmental impact / consequences — “Climate change is real. We need to do something about this” | |||||
| ▸32 | June 11, 2026 | Lawrence A. Cunningham, on behalf of 19 finance & law professors | Support rescission | Academic researcher | 1A AUTH CAPFORM CB CBA CFR ENV FRAG IMMAT INSUFF IP PP REDUN |
Position: Support rescission (unanimous) · Entity: Academic researcher (unanimous) Modification posture: No modification requested — no substantive request to change the framework 1A Compelled speech / First Amendment (either direction) — “C. Risk of Unconstitutional Compelled Political Speech” AUTH Statutory authority / major-questions (either direction) — “passions of this topic have led the SEC to overzealous rulemaking that exceeds its” CAPFORM Market efficiency / capital formation — “companies into private equity rather than public markets. That impairs capital formation through” CB Compliance burden — “would have imposed substantial compliance, legal, auditing, and governance costs while” CBA Cost-benefit assessment — “The Proposal follows the form of cost-benefit analysis expected of U.S. federal agencies.” CFR Climate-related financial risk — “technology and telecommunications, which face limited climate-related risks” ENV Environmental impact / consequences — “Proposal, even if implemented, will not have a meaningful impact on climate change.” FRAG Regulatory fragmentation / multi-jurisdictional consistency — “other countries in which a registrant operates may have adopted more stringent climate-related” IMMAT Immaterial / not decision-useful — “reason is that much climate information is not material.” INSUFF Insufficient / incoherent legal basis (either direction) IP Investor protection / decision usefulness — “statutory authority to require disclosures for the protection of investors” PP Political pressure / regulatory capture — “the Proposal seems to be heavily influenced by a small but powerful cohort of” REDUN Redundant — existing rules, materiality regime, or voluntary reporting already suffice — “climate-related information through current SEC disclosure requirements, voluntary reporting, and” | |||||
| ▸31 | June 11, 2026 | Laura Miller | Oppose rescission | Individual | ACCT CFR IP |
Position: Oppose rescission (majority) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework ACCT Stewardship / accountability — “I urge the SEC to preserve the shareholder proposal rule as a cornerstone of property rights and free-market accountability” CFR Climate-related financial risk — “risks that eventually become losses borne by ordinary shareholders like myself” IP Investor protection / decision usefulness — “Climate-related disclosures ARE material to investment strategy” | |||||
| ▾ June 10, 2026 2 letters | |||||
| ▸30 | June 10, 2026 | Theodore Weber & Andrew Carter, Defenders of Wildlife | Oppose rescission | Environmental / ESG advocacy org | Modify / Expand ACCT CFR CMP DEMAND ENV IP |
Position: Oppose rescission (unanimous) · Entity: Environmental / ESG advocacy org (unanimous) Modification posture: Modify / Expand — asks for stronger or broader disclosure ACCT Stewardship / accountability — “the reporting of real data to back up claims” CFR Climate-related financial risk — “Investors need information about climate-related risks because climate-related risks have financial” CMP Standardization / comparability — “It helps bring consistency and standardization to these reportings” DEMAND Investor demand / fund reliance — “Investors expressed a need” ENV Environmental impact / consequences — “the 2024 amendments could also have significant climate mitigation and adaptation” IP Investor protection / decision usefulness — “These measures can help investors make informed choices about their investments.” | |||||
| ▸29 | June 10, 2026 | Anonymous | Oppose rescission | Individual | ACCT CFR DEMAND ENV IP |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework ACCT Stewardship / accountability — “Public held companies should be responsible for their practices” CFR Climate-related financial risk — “determine the health and viability of the public held corporation” DEMAND Investor demand / fund reliance — “As a long time investor, I use climate related information to invest in environmental conscious public companies.” ENV Environmental impact / consequences — “Without this information, investors will be harmed as well as our environment.” IP Investor protection / decision usefulness — “Climate related disclosures should be required to help investors determine” | |||||
| ▾ June 9, 2026 2 letters | |||||
| ▸28 | June 9, 2026 | Theresa Alberici | Oppose rescission | Individual | ACCT ENV |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework ACCT Stewardship / accountability — “Corporations should absolutely have to continue to report on any substances and discharges that may affect changes to our climate!” ENV Environmental impact / consequences — “These substances may contribute to climate change which affects us now and will affect future generations” | |||||
| ▸27 | June 9, 2026 | Matthias Perczynski | Oppose rescission | Individual | Modify / Improve or Clarify AUTH CAPFORM CBA CFR CMP DEMAND ENV FRAG IP |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: Modify / Improve or Clarify — asks for a revised, clarified or better-designed framework AUTH Statutory authority / major-questions (either direction) CAPFORM Market efficiency / capital formation — “Your proposal to rescind these disclosure rules creates inefficient markets, the antithesis of free and fair markets.” CBA Cost-benefit assessment — “What if the cost savings on public companies turns into a decrease in healthier environmental practices, thus throwing tangible and intangible costs to stakeholders?” CFR Climate-related financial risk — “Climate risk is an ascending factor that impacts shareholder value.” CMP Standardization / comparability — “I believe standardization of climate-related disclosure should fall squarely within the boundaries of the SEC's reach” DEMAND Investor demand / fund reliance — “I've used data to align my investments with companies I believe are better positioned to manage long-term risk” ENV Environmental impact / consequences — “passing the costs of degrading environments onto those who can't afford” FRAG Regulatory fragmentation / multi-jurisdictional consistency — “investors are left to comb through data from voluntary reports, state-specific rules, and international standards” IP Investor protection / decision usefulness — “climate-related disclosures aid in the protection of investors” | |||||
| ▾ June 8, 2026 3 letters | |||||
| ▸26 | June 8, 2026 | Ross Vandegrift | Oppose rescission | Individual | ACCT ENV IP |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework ACCT Stewardship / accountability — “we need to ensure that public companies report on their relevant actions” ENV Environmental impact / consequences — “The future of the Earth's climate is the most important problem humans have ever confronted” IP Investor protection / decision usefulness — “so consumers and investors can make reasonable judgments about their behavior” | |||||
| ▸25 | June 8, 2026 | Nancy K Murphy | Oppose rescission | Individual | IP |
Position: Oppose rescission (majority) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework IP Investor protection / decision usefulness — “If I cannot trust you to look out for my investment interests” | |||||
| ▸24 | June 8, 2026 | Leslie Turpin | Oppose rescission | Individual | ACCT CB ENV |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework ACCT Stewardship / accountability — “we will be ignorant to the causes and accountability measures needed to sustain the planet” CB Compliance burden — “The economic burden should lie with those profiting from those practices.” ENV Environmental impact / consequences — “accountability is key to preventing disasters related to ecological degradation” | |||||
| ▾ June 6, 2026 1 letter | |||||
| ▸23 | June 6, 2026 | Justin Horowitz, Certified Financial Planner | Oppose rescission | Individual | Modify / Improve or Clarify AUTH CBA CFR CMP DEMAND ENV FRAG IP |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: Modify / Improve or Clarify — asks for a revised, clarified or better-designed framework AUTH Statutory authority / major-questions (either direction) CBA Cost-benefit assessment — “What if the cost savings on public companies turns into a decrease in healthier environmental practices, thus throwing tangible and intangible costs to stakeholders?” CFR Climate-related financial risk — “information I believe materially impacts corporate financial performance” CMP Standardization / comparability — “I believe standardization of climate-related disclosure should fall squarely within the bounds of the SEC's reach” DEMAND Investor demand / fund reliance — “I've used data to align my investments with companies I believe are better positioned to manage long-term risk” ENV Environmental impact / consequences — “a decrease in healthier environmental practices” FRAG Regulatory fragmentation / multi-jurisdictional consistency — “investors are left to comb through data from voluntary reports, state-specific rules, and international standards” IP Investor protection / decision usefulness — “climate-related disclosures aid in the protection of investors” | |||||
| ▾ June 5, 2026 2 letters | |||||
| ▸22 | June 5, 2026 | Patrick Bradley | Oppose rescission | Individual | Fallback / Compromise 1A AUTH CB CBA CFR CMP DEMAND FRAG INSUFF IP WHIP GHG12 |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: Fallback / Compromise — primary position is clear; a second-best alternative is offered if it is rejected Keep provisions: GHG12 (Scope 1 & 2 emissions) 1A Compelled speech / First Amendment (either direction) AUTH Statutory authority / major-questions (either direction) CB Compliance burden — “fragmentation and compliance cost for cross-listed issuers” CBA Cost-benefit assessment — “that figure counts only avoided compliance costs” CFR Climate-related financial risk — “information about the financial effects of climate-related” CMP Standardization / comparability — “consistent, comparable, and reliable information” DEMAND Investor demand / fund reliance — “findings on investor demand, materiality, and cost-justification” FRAG Regulatory fragmentation / multi-jurisdictional consistency — “Eliminating a federal floor while California and foreign regimes remain in force increases” INSUFF Insufficient / incoherent legal basis (either direction) IP Investor protection / decision usefulness — “institutional investors incorporated the expected disclosures into valuation and” WHIP Regulatory whiplash / reliance interests / costs already incurred — “Issuers anticipating the rules built greenhouse-gas inventories, internal controls” | |||||
| ▸21 | June 5, 2026 | Donna Zhou | No position | Individual | CB CBA CFR CMP ENV FRAG IMMAT |
Position: No position (majority) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework CB Compliance burden — “eliminating redundant emissions accounting and duplicate reporting burdens for individual reporting entities” CBA Cost-benefit assessment — “How substantial is the practical value of obliging companies to merely disclose greenhouse gas inventories and climate risk data?” CFR Climate-related financial risk — “The transmission pathway from environmental metrics to corporate financial performance is far more than straightforward numerical calculation” CMP Standardization / comparability — “The federal government could establish a centralized unified public database platform alongside standardized official data validation protocols.” ENV Environmental impact / consequences — “Additionally, does the Earth's intrinsic ecosystem possess self-regulating mechanisms to mitigate and balance climatic fluctuations?” FRAG Regulatory fragmentation / multi-jurisdictional consistency — “I propose that the U.S. Environmental Protection Agency (EPA) and the U.S. Securities and Exchange Commission (SEC) jointly deliberate on the formulation of climate disclosure regulations.” IMMAT Immaterial / not decision-useful — “Reliably evaluating the material impacts of climate-related factors on corporations and investors cannot be achieved solely through routine risk identification and mandatory data disclosure requirements.” | |||||
| ▾ June 4, 2026 6 letters | |||||
| ▸20 | June 4, 2026 | Michael Adkins | Oppose rescission | Individual | ENV |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework ENV Environmental impact / consequences — “It is important to know how a company impacts climate.” | |||||
| ▸19 | June 4, 2026 | John Friedman | Oppose rescission | Individual | Fallback / Compromise CFR CMP IP |
Position: Oppose rescission (majority) · Entity: Individual (unanimous) Modification posture: Fallback / Compromise — primary position is clear; a second-best alternative is offered if it is rejected CFR Climate-related financial risk — “requiring an evaluation of physical risks to properties” CMP Standardization / comparability — “without consistent, comparable and decision-useful data provided by property owners” IP Investor protection / decision usefulness — “provide investors with a reasonable understanding of the risk of their investments” | |||||
| ▸18 | June 4, 2026 | Alex Lee | Oppose rescission | Individual | NR |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework NR No substantive rationale | |||||
| ▸17 | June 4, 2026 | Colleen Wold | Mixed | Issuer / Corporate — current | Modify / Reduce ACCT CB CBA CFR CMP FRAG IMMAT IP REDUN GOV |
Position: Mixed (unanimous) · Entity: Issuer / Corporate — current (majority) Modification posture: Modify / Reduce — asks for fewer or more limited requirements Keep provisions: GOV (Governance / risk management) ACCT Stewardship / accountability — “board oversight, management accountability, and risk governance” CB Compliance burden — “avoids imposing unnecessary compliance burdens that may not provide commensurate investor benefit” CBA Cost-benefit assessment — “they should be recognized as part of the cost-benefit analysis associated with a more principles-based framework” CFR Climate-related financial risk — “material climate-related risks when they materially affect strategy, operations, liquidity, financial condition, or long-term enterprise value” CMP Standardization / comparability — “consistency and comparability will increasingly depend on how registrants assess and apply materiality” FRAG Regulatory fragmentation / multi-jurisdictional consistency — “the growing patchwork of climate-related reporting requirements at the state, international, investor, lender, and customer level” IMMAT Immaterial / not decision-useful — “highly prescriptive quantitative reporting requirements that may not be decision-useful for all investors” IP Investor protection / decision usefulness — “disclosures regarding governance and oversight often provide more decision-useful information” REDUN Redundant — existing rules, materiality regime, or voluntary reporting already suffice — “Existing disclosure requirements already require companies to evaluate and disclose material risks, trends, uncertainties, and factors” | |||||
| ▸16 | June 4, 2026 | Troutt | Support rescission | Individual | CAPFORM INSUFF PP |
Position: Support rescission (majority) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework CAPFORM Market efficiency / capital formation — “at odds with the Commission’s policy objectives of facilitating capital formation and promoting public company status” INSUFF Insufficient / incoherent legal basis (either direction) PP Political pressure / regulatory capture — “misappropriated agency/index objectives in order to obviate any capital market-RICO recurrence” | |||||
| ▸15 | June 4, 2026 | Isaiah Oluwasegun Owolabi, Founder & CEO, ESGine | No position | Issuer / Corporate — current | CB CBA CMP IP WHIP |
Position: No position (split) · Entity: Issuer / Corporate — current (unanimous) Modification posture: No modification requested — no substantive request to change the framework CB Compliance burden — “It also raises reasonable questions about compliance costs” CBA Cost-benefit assessment — “whether those costs are justified by the benefits provided to investors” CMP Standardization / comparability — “helping companies make materiality decisions that are clear, consistent, defensible, and useful to investors” IP Investor protection / decision usefulness — “Investors benefit most when disclosures focus on information that is genuinely important to investment and voting decisions.” WHIP Regulatory whiplash / reliance interests / costs already incurred — “regulatory uncertainty creates costs of its own” | |||||
| ▾ June 3, 2026 1 letter | |||||
| ▸14 | June 3, 2026 | Dr. James Holdman | Oppose rescission | Individual | CFR ENV IP |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework CFR Climate-related financial risk — “Climate change poses risks to financial markets, material risks to corporate profits” ENV Environmental impact / consequences — “Corporate emissions are the largest contributor to climate change.” IP Investor protection / decision usefulness — “material risks to corporate profits and therefore to investors” | |||||
| ▾ June 2, 2026 1 letter | |||||
| ▸13 | June 2, 2026 | Draca, Series 7 licensed | Oppose rescission | Investor / asset manager (institutional) | ACCT CB ENV IP |
Position: Oppose rescission (unanimous) · Entity: Investor / asset manager (institutional) (majority) Modification posture: No modification requested — no substantive request to change the framework ACCT Stewardship / accountability — “removing corporate accountability” CB Compliance burden — “The whining about the time it takes to fill out the reports should be ignored” ENV Environmental impact / consequences — “many of us believe in climate change” IP Investor protection / decision usefulness — “keep information that helps investors choose companies aligned with their values” | |||||
| ▾ June 1, 2026 3 letters | |||||
| ▸12 | June 1, 2026 | Casey Bessemer | Oppose rescission | Individual | ACCT CB CBA DEMAND ENV INSUFF IP |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework ACCT Stewardship / accountability — “the resistance to such disclosures only reveals a willingness to defraud investors” CB Compliance burden — “Requiring climate disclosure is not only a small burden upon corporations” CBA Cost-benefit assessment — “not only a small burden upon corporations, but to not disclose this information is tantamount to withholding valuable investment information” DEMAND Investor demand / fund reliance — “There are investors that want to invest in climate friendly initiatives and corporations” ENV Environmental impact / consequences — “Many scientists have proven that climate change is an existential threat to humanity as a whole.” INSUFF Insufficient / incoherent legal basis (either direction) IP Investor protection / decision usefulness — “The disclosures are necessary for individual investors to make informed investment decisions” | |||||
| ▸11 | June 1, 2026 | Neil P. Osnato | Support rescission | Issuer / Corporate — current | Modify / Reduce CBA CFR IMMAT IP REDUN |
Position: Support rescission (majority) · Entity: Issuer / Corporate — current (unanimous) Modification posture: Modify / Reduce — asks for fewer or more limited requirements CBA Cost-benefit assessment — “registrant-specific materiality and disproportionate to their
investor-useful benefits.” CFR Climate-related financial risk — “Does the risk materially affect the registrant’s business, cash flow,” IMMAT Immaterial / not decision-useful — “Investors do not benefit from disclosure volume that obscures the” IP Investor protection / decision usefulness — “Disclosure should be material, decision-useful, financially relevant,” REDUN Redundant — existing rules, materiality regime, or voluntary reporting already suffice — “existing disclosure obligations already require public companies to” | |||||
| ▸10 | June 1, 2026 | David Dolbashian | Oppose rescission | Individual | CAPFORM CFR ENV IP |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework CAPFORM Market efficiency / capital formation — “Your proposal to rescind these disclosure rules creates inefficient markets” CFR Climate-related financial risk — “Changes to the environment impact corporate investments and assets at an alarming rate.” ENV Environmental impact / consequences — “The political economy is factoring in the environmental costs to humanity” IP Investor protection / decision usefulness — “Open and free markets necessitate full disclosure of information. Climate risk is an ascending factor that impacts shareholder value.” | |||||
| ▾ May 31, 2026 3 letters | |||||
| ▸9 | May 31, 2026 | Andrea Joy Kendall, Retired Fortune 500 IT International Team Leader | Oppose rescission | Individual | CFR IP |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework CFR Climate-related financial risk — “Given the direct correlation between climate change and risks to certain sectors this information is an important part of making wise decisions.” IP Investor protection / decision usefulness — “As an investor I have the right to information on which to make decisions on my investments.” | |||||
| ▸8 | May 31, 2026 | Ellen Travis | Oppose rescission | Individual | ACCT AUTH CAPFORM CB CBA CFR CMP DEMAND INSUFF IP |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework ACCT Stewardship / accountability — “Without mandatory standards, companies cherry-pick favorable metrics, limiting comparability and accuracy” AUTH Statutory authority / major-questions (either direction) CAPFORM Market efficiency / capital formation — “companies find climate disclosure valuable for capital formation, not merely burdensome” CB Compliance burden — “Rather than dismissing compliance costs” CBA Cost-benefit assessment — “the Commission should weigh them against investor gains” CFR Climate-related financial risk — “recognizes that climate risks can materially impact financial performance” CMP Standardization / comparability — “By requiring consistent, comparable climate disclosures” DEMAND Investor demand / fund reliance — “suggesting investor demand for this information is significant” INSUFF Insufficient / incoherent legal basis (either direction) IP Investor protection / decision usefulness — “represents a misguided and contradictory retreat from investor protection” | |||||
| ▸7 | May 31, 2026 | he stock market sharing | Off-topic | Individual | |
Position: Off-topic (unanimous) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework No coded rationale. | |||||
| ▾ May 30, 2026 1 letter | |||||
| ▸6 | May 30, 2026 | Patty Mulvihill, Retired Educator | Oppose rescission | Individual | ACCT ENV PP |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework ACCT Stewardship / accountability — “Corporations and other entities have a responsibility to act in the public interests.” ENV Environmental impact / consequences — “Clean air and water is a right that every American must count on for the health of there families and communities.” PP Political pressure / regulatory capture — “This proposed rescission reeks of corporations wanting to protect their investors and the bottom line of these entities.” | |||||
| ▾ May 29, 2026 4 letters | |||||
| ▸5 | May 29, 2026 | S. | Oppose rescission | Individual | NR |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework NR No substantive rationale | |||||
| ▸4 | May 29, 2026 | Eileen Morrell, Corporate Finance Professional | Support rescission | Individual | NR |
Position: Support rescission (unanimous) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework NR No substantive rationale | |||||
| ▸3 | May 29, 2026 | Anonymous | Support rescission | Individual | NR |
Position: Support rescission (unanimous) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework NR No substantive rationale | |||||
| ▸2 | May 29, 2026 | Bruce Lee Lenker | Off-topic | Individual | |
Position: Off-topic (unanimous) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework No coded rationale. | |||||
| ▾ May 28, 2026 1 letter | |||||
| ▸1 | May 28, 2026 | David Way | Oppose rescission | Individual | ACCT CFR IP PP |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework ACCT Stewardship / accountability — “companies that are bad actors will take every opportunity to hide the information if not compelled to comply by federal rules” CFR Climate-related financial risk — “will continue to cause some of the biggest financial impacts to the global economy” IP Investor protection / decision usefulness — “essential information for share holders to have when making decisions about their investments” PP Political pressure / regulatory capture — “an attempt by the federal government to hurt investors in the short and long term by helping companies in the short term” | |||||