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.
11,634 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 713 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
6,718 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 713 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
34 submitters filed the SEC Type C 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 713 individual letters and never summed into the stance counts (the campaign total is anonymous and may overlap with named letters).
Rationale tags: IP CFR CMP ENV
| # | Date | Name | Position | Entity | Rationales |
|---|---|---|---|---|---|
| ▾ August 25, 2026 1 letter | |||||
| ▸713 | Aug. 25, 2026 | Doris Verkamp | Oppose rescission | Individual | CFR CMP DEMAND FRAG IP |
Position: Oppose rescission (majority) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework CFR Climate-related financial risk — “underscore the accelerating financial and infrastructure risks to communities, companies, and investors” CMP Standardization / comparability — “a range of confusing and overlapping standards and guidelines” DEMAND Investor demand / fund reliance — “hundreds of investors who collectively own or manage more than $50 trillion in assets showed that they supported the SEC's climate disclosure rule” FRAG Regulatory fragmentation / multi-jurisdictional consistency — “both within and outside the United States” IP Investor protection / decision usefulness — “they needed this information for their investment and voting decisions” | |||||
| ▾ August 22, 2026 1 letter | |||||
| ▸712 | Aug. 22, 2026 | Barbara Hoover | 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 — “most people really are watching the climate” | |||||
| ▾ August 21, 2026 1 letter | |||||
| ▸711 | Aug. 21, 2026 | Liana McIsaac | Oppose rescission | Individual | CMP ENV |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework CMP Standardization / comparability — “more consistent, comparable, and accessible” ENV Environmental impact / consequences — “Communities would lose a critical public source of environmental data.” | |||||
| ▾ August 15, 2026 1 letter | |||||
| ▸710 | Aug. 15, 2026 | Jane Clevenger, Co-Founder of Renewables Now Loveland | Oppose rescission | Environmental / ESG advocacy org | ENV PP |
Position: Oppose rescission (unanimous) · Entity: Environmental / ESG advocacy org (majority) Modification posture: No modification requested — no substantive request to change the framework ENV Environmental impact / consequences — “We can NOT afford to go backwards in addressing our planet warming and causing so many to suffer.” PP Political pressure / regulatory capture — “Don't let freaks convince you how great it would be to let the corporations have their way with our government.” | |||||
| ▾ August 13, 2026 2 letters | |||||
| ▸706 | Aug. 13, 2026 | Donna Wright | Oppose rescission | Individual | Modify / Expand CFR ENV IP |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: Modify / Expand — asks for stronger or broader disclosure CFR Climate-related financial risk — “account for severe-weather losses, calculate certain emissions” ENV Environmental impact / consequences — “We should be strengthening our rules to protect our national natural resources, not weakening them.” IP Investor protection / decision usefulness — “Climate disclosures can help investors and the public understand how companies identify significant climate risks” | |||||
| ▸705 | Aug. 13, 2026 | David R. Burton, Senior Fellow in Economic Policy, Advancing American Freedom | Support rescission | Business trade association / advocacy org | 1A ACCT AUTH CAPFORM CB CBA ENV FRAG IMMAT INSUFF IP PP REDUN |
Position: Support rescission (unanimous) · Entity: Business trade association / advocacy org (unanimous) Modification posture: No modification requested — no substantive request to change the framework 1A Compelled speech / First Amendment (either direction) — “The Rule Constitutes Unconstitutional Compelled Speech.” ACCT Stewardship / accountability — “ESG Requirements will Make Management Even Less Accountable.” AUTH Statutory authority / major-questions (either direction) — “securities laws do not give the Commission the authority to impose regulations” CAPFORM Market efficiency / capital formation — “The number of IPOs will decline.” CB Compliance burden — “demand radically higher fees to compensate for litigation risk.” CBA Cost-benefit assessment — “The Commission’s Economic Analysis is Seriously Deficient.” ENV Environmental impact / consequences — “Trying to achieve environmental results through mandated disclosures by issuers” FRAG Regulatory fragmentation / multi-jurisdictional consistency — “property rights, tort law, and regulation (by the EPA, for example).” IMMAT Immaterial / not decision-useful — “Only material information should be presented.” INSUFF Insufficient / incoherent legal basis (either direction) — “The releases entirely skip the analytical or factual predicate for the rulemaking” IP Investor protection / decision usefulness — “investors will find it more difficult to determine relevant information material” PP Political pressure / regulatory capture — “the disclosure is weaponized by a highly politicized SEC” REDUN Redundant — existing rules, materiality regime, or voluntary reporting already suffice — “Incorporating climate change disclosure mandates beyond those already required” | |||||
| ▾ August 12, 2026 1 letter | |||||
| ▸704 | Aug. 12, 2026 | Anthony Conte | Support rescission | Individual | 1A AUTH CAPFORM CB CBA DEMAND IMMAT INSUFF PP REDUN |
Position: Support rescission (unanimous) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework 1A Compelled speech / First Amendment (either direction) — “the disclosures amount to compelled speech that likely would not survive a court challenge” AUTH Statutory authority / major-questions (either direction) — “the SEC never had statutory authority to require climate-related reporting in the first place” CAPFORM Market efficiency / capital formation — “policy objectives of facilitating capital formation and promoting public company status” CB Compliance burden — “moving to rescind an illegitimate and burdensome imposition on the investing public” CBA Cost-benefit assessment — “The Final Rules do impose substantial costs that are not justified by the informational benefits they may provide to some investors” DEMAND Investor demand / fund reliance — “Not only have ESG-themed investing funds seen massive outflows and declines in investor interest” IMMAT Immaterial / not decision-useful — “The Final Rules are unnecessary and inconsistent with a registrant-specific, materiality-based approach to disclosure” INSUFF Insufficient / incoherent legal basis (either direction) — “The agency has also been selective about citing industry trends and corporate investment decisions that support the pro-ESG/sustainability narrative.” PP Political pressure / regulatory capture — “industry participants had a tremendous interest in promoting a regulatory framework that further entrenched it” REDUN Redundant — existing rules, materiality regime, or voluntary reporting already suffice — “leave the supply of detailed information on climate-themed corporate operations to those data providers best situated to provide it in a competitive marketplace” | |||||
| ▾ August 10, 2026 2 letters | |||||
| ▸703 | Aug. 10, 2026 | James Quinn | 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 — “to avoid any accountability for their actions” ENV Environmental impact / consequences — “making Earth unlivable for humans” PP Political pressure / regulatory capture — “This is a cowardly rule, clearly an attempt by corporations” | |||||
| ▸702 | Aug. 10, 2026 | David L. Ulery, CEO at Tornadic Entertainment, LLC | Oppose rescission | Issuer / Corporate — current | Fallback / Compromise ACCT AUTH CAPFORM CB CBA CFR CMP FRAG IP |
Position: Oppose rescission (unanimous) · Entity: Issuer / Corporate — current (majority) Modification posture: Fallback / Compromise — primary position is clear; a second-best alternative is offered if it is rejected ACCT Stewardship / accountability — “accountability within the federal securities disclosure system” AUTH Statutory authority / major-questions (either direction) — “excessively costly, burdensome, or beyond its authority” CAPFORM Market efficiency / capital formation — “The SEC's central mission includes protecting investors and maintaining fair and efficient markets.” CB Compliance burden — “targeted revisions that reduce unnecessary compliance burdens” CBA Cost-benefit assessment — “Complete rescission should be a last resort when narrower alternatives could address legitimate compliance concerns while preserving useful investor protections.” CFR Climate-related financial risk — “can have significant financial consequences for companies and their shareholders” CMP Standardization / comparability — “makes meaningful comparison among companies more difficult” FRAG Regulatory fragmentation / multi-jurisdictional consistency — “information scattered among SEC filings, sustainability reports, corporate websites, and state or international reporting systems” IP Investor protection / decision usefulness — “Investors should have access to consistent, comparable, and reliable information concerning material risks” | |||||
| ▾ August 9, 2026 3 letters | |||||
| ▸701 | Aug. 9, 2026 | Terry Wilson | Oppose rescission | Individual | ENV PP |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework ENV Environmental impact / consequences — “believe in unborn generations who want clean air and water.” PP Political pressure / regulatory capture — “Do not bow to the money” | |||||
| ▸700 | Aug. 9, 2026 | Levi Buckley | Oppose rescission | Individual | CMP ENV |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework CMP Standardization / comparability — “make significant climate-related information more consistent, comparable, and accessible” ENV Environmental impact / consequences — “We're in the middle of a climate crisis, and now is not the time to worry if that's politically correct or convenient.” | |||||
| ▸699 | Aug. 9, 2026 | James Byrne | Oppose rescission | Individual | CFR DEMAND 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 — “decisions on climate risk both financially and morally” DEMAND Investor demand / fund reliance — “It is a vital piece of information that I strongly support in regulating companies to continue to provide this data to all investors.” IP Investor protection / decision usefulness — “as an individual investor I use data from companies to make decisions on climate risk” | |||||
| ▾ August 8, 2026 1 letter | |||||
| ▸698 | Aug. 8, 2026 | Delmar M. Fadden | 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 — “Understanding who is helping to mitigate the effects is essential information.” ENV Environmental impact / consequences — “The effects of climate change are all around me.” | |||||
| ▾ August 7, 2026 2 letters | |||||
| ▸697 | Aug. 7, 2026 | Tracy Leigh Feldman | Oppose rescission | Individual | CAPFORM FRAG 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 — “Rescinding this rule would be a step backward for U.S. markets” FRAG Regulatory fragmentation / multi-jurisdictional consistency — “More than 40 countries-representing 60 percent of global GDP-have approved or proposed climate disclosure rules of their own.” IP Investor protection / decision usefulness — “the millions of Americans whose financial futures depend on their investments” | |||||
| ▸696 | Aug. 7, 2026 | B. Jay | Oppose rescission | Individual | CMP IP |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework CMP Standardization / comparability — “make significant climate-related information more consistent, comparable, and accessible” IP Investor protection / decision usefulness — “Communities and investors would lose a critical public source of data.” | |||||
| ▾ August 6, 2026 3 letters | |||||
| ▸695 | Aug. 6, 2026 | Susan Luenser | Support rescission | Individual | AUTH CB CBA IMMAT |
Position: Support rescission (unanimous) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework AUTH Statutory authority / major-questions (either direction) — “The rule far exceeds the agency’s legislative authorization.” CB Compliance burden — “It increases costs for businesses and for their suppliers and customers.” CBA Cost-benefit assessment — “The rule increases the prices of goods and services while providing no immediate benefit that has been defined by congressional law according to congressionally-established metrics.” IMMAT Immaterial / not decision-useful — “disseminates irrelevant information” | |||||
| ▸694 | Aug. 6, 2026 | Linda Millemaci | 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 — “The public needs to be aware without restrictions and disclose everything related to climate change” | |||||
| ▸693 | Aug. 6, 2026 | Cindy Anderson | 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 — “Climate change is killing us.” IP Investor protection / decision usefulness — “I dont want to invest or use companies that harm our world.” PP Political pressure / regulatory capture — “Don't let the Trump idiocy influence the SEC.” | |||||
| ▾ August 5, 2026 7 letters | |||||
| ▸692 | Aug. 5, 2026 | Melissa Baldridge, Big Glasses Consulting, PBC | Oppose rescission | Individual | CFR IP PP |
Position: Oppose rescission (unanimous) · Entity: Individual (majority) Modification posture: No modification requested — no substantive request to change the framework CFR Climate-related financial risk — “how risky a company is based on their carbon-intensity” IP Investor protection / decision usefulness — “you are stripping investors of a key piece of information” PP Political pressure / regulatory capture — “the U.S. Supreme Court overturns this politicized decision” | |||||
| ▸691 | Aug. 5, 2026 | Mary Stan | 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 — “Please don’t Climate rescisend data or funds” | |||||
| ▸690 | Aug. 5, 2026 | Lou Priem, Physician | Oppose rescission | Individual | ENV INSUFF |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework ENV Environmental impact / consequences — “observing all the climate destruction from the increased rain, flooding, hot weather and fire” INSUFF Insufficient / incoherent legal basis (either direction) — “I am not sure how there can be any justification for a reduction in climate monitoring and healthy airway activity.” | |||||
| ▸689 | Aug. 5, 2026 | Cara Diaconoff, Professor of English, Bellevue College | 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 — “It is vital that investors have climate change information.” | |||||
| ▸688 | Aug. 5, 2026 | Barbara Darnell | Oppose rescission | Individual | Modify / Expand CMP ENV FRAG IP |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: Modify / Expand — asks for stronger or broader disclosure CMP Standardization / comparability — “make significant climate-related information more consistent, comparable, and accessible” ENV Environmental impact / consequences — “Communities would lose a critical public source of environmental data.” FRAG Regulatory fragmentation / multi-jurisdictional consistency — “voluntary sustainability reports, state disclosure systems, and other company materials” IP Investor protection / decision usefulness — “Investors could instead be required to locate information across general SEC filings, voluntary sustainability reports, state disclosure systems, and other company materials.” | |||||
| ▸437 | Aug. 5, 2026 | C. Edward Allen, Senior Director, Corporate Finance Policy and Jake Kuhns Vice President, Domestic Policy, National Association of Manufacturers | Support rescission | Business trade association / advocacy org | AUTH CAPFORM CB CBA CFR IMMAT INSUFF IP REDUN |
Position: Support rescission (unanimous) · Entity: Business trade association / advocacy org (unanimous) Modification posture: No modification requested — no substantive request to change the framework AUTH Statutory authority / major-questions (either direction) — “the NAM agrees that the Commission lacks the statutory authority to adopt such a far-reaching regulation mandating climate disclosures.” CAPFORM Market efficiency / capital formation — “manufacturers agree that the proposed rescission of the 2024 Rule and the Commission's return to the issuer-specific 2010 Guidance would broadly benefit market efficiency, competition, and capital formation.” CB Compliance burden — “issuers would have to spend a significant amount of money just to ascertain if they are required to disclose their emissions.” CBA Cost-benefit assessment — “the substantial costs of the 2024 Rule are not justified by the informational benefits that this rule may provide to some investors.” CFR Climate-related financial risk — “climate-related risks may be material for companies in certain manufacturing sectors” IMMAT Immaterial / not decision-useful — “"the Commission has decorated the final rule with materiality ribbons" but "the rule embraces materiality in name only."” INSUFF Insufficient / incoherent legal basis (either direction) — “the rule's breadth suggests a different purpose.” IP Investor protection / decision usefulness — “investors already are receiving climate-related information from the public companies that comprise the vast majority of their holdings.” REDUN Redundant — existing rules, materiality regime, or voluntary reporting already suffice — “manufacturers already are providing material climate-related information to their shareholders” | |||||
| ▸436 | Aug. 5, 2026 | Allan Moskiwitz, Certified Financial Planner, Transformative Wealth Management | Oppose rescission | Investor / asset manager (institutional) | ACCT AUTH CAPFORM CFR CMP DEMAND 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 — “The rules slated for rescission would have required companies to explicitly disclose board oversight of climate related 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 — “Climate-related risks will have a seismic effect on economic growth and need to be taken seriously when calculating the economic effects of regulatory changes.” CMP Standardization / comparability — “The proposed rescission represents a significant step backward for market transparency by denying investors access to standardized, comparable data.” DEMAND Investor demand / fund reliance — “Investors have been calling for increased disclosure and regulation around climate-related risks for decades” 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 — “Standardized, mandatory climate disclosures are not a departure from the SEC's mission; they are an essential tool for modern investor protection and capital allocation.” | |||||
| ▾ August 4, 2026 40 letters | |||||
| ▸687 | Aug. 4, 2026 | Theresa Bucher | Oppose rescission | Individual | Modify / Expand ENV |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: Modify / Expand — asks for stronger or broader disclosure ENV Environmental impact / consequences — “Climate change is real and becoming increasingly costly to all.” | |||||
| ▸686 | Aug. 4, 2026 | Sharon Baker | Oppose rescission | Individual | Modify / Expand ENV |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: Modify / Expand — asks for stronger or broader disclosure ENV Environmental impact / consequences — “When all the trees and animals are dead and all the air, land and water are polluted” | |||||
| ▸685 | Aug. 4, 2026 | Patty Baum | 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 — “The healthcare of Americans is at stake!!!!” | |||||
| ▸684 | Aug. 4, 2026 | Patricia Goodson | 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 need to stop pollution in order to do that!” | |||||
| ▸683 | Aug. 4, 2026 | Pamela T. Wright | Oppose rescission | Individual | ENV PP |
Position: Oppose rescission (majority) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework ENV Environmental impact / consequences — “Everyone should be aware of climate change” PP Political pressure / regulatory capture — “regardless of views from the White House.” | |||||
| ▸682 | Aug. 4, 2026 | Pam Krimsky | 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 are only concerned with the bottom line - the cost.” ENV Environmental impact / consequences — “Clean Air is Essential to All life.” | |||||
| ▸681 | Aug. 4, 2026 | Naomi Gusowski, Math Tutor | 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 scientifically substantiated and citizens should be made aware of this threat to the future.” | |||||
| ▸680 | Aug. 4, 2026 | Mrs. Lori Gonsalves | 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 — “give large corporations an out of responsibility to the country” ENV Environmental impact / consequences — “especially as we face severe weather across the entire country” PP Political pressure / regulatory capture — “I believe this is an attempt to silence the truth” | |||||
| ▸679 | Aug. 4, 2026 | Mary Fifield | Oppose rescission | Individual | Modify / Expand CB CBA CFR ENV IP |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: Modify / Expand — asks for stronger or broader disclosure CB Compliance burden — “Such disclosures are not an unreasonable requirement for public companies” CBA Cost-benefit assessment — “given the enormous costs to the broader economy when those disclosures are not clear, accessible, and complete” CFR Climate-related financial risk — “are a current and long-term threat to our economy” ENV Environmental impact / consequences — “Record-setting weather disasters that are exacerbated by climate change and will only get worse” IP Investor protection / decision usefulness — “for investors to access transparent information about companies' climate-related decisions and practices” | |||||
| ▸678 | Aug. 4, 2026 | Mary C Bouajila, Semi-Retired Teacher | Oppose rescission | Individual | ACCT CFR ENV IP |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework ACCT Stewardship / accountability — “Rolling back the protections allows greedy corporations' profits rather than supporting working people, families and our communities.” CFR Climate-related financial risk — “material climate-related risks in registration statements and annual reports” ENV Environmental impact / consequences — “Do the right thing for humanity (we the People) and our home (land, earth).” IP Investor protection / decision usefulness — “provide investors with information about material climate-related risks” | |||||
| ▸677 | Aug. 4, 2026 | Kate Rojas | 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 — “I'm also concerned that communities would lose a critical public source of environmental data.” | |||||
| ▸676 | Aug. 4, 2026 | Karen Gravereaux | 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 — “including the government, universities and corporations should be shared transparently with the public” | |||||
| ▸675 | Aug. 4, 2026 | Julie Adelson | Oppose rescission | Individual | Modify / Expand ENV |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: Modify / Expand — asks for stronger or broader disclosure ENV Environmental impact / consequences — “the destruction of life on Earth due to human fossil activity” | |||||
| ▸674 | Aug. 4, 2026 | Joe LeBlanc | 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 — “You are jeopardizing the future for your children, grandchildren and everyone else that lives on this planet.” | |||||
| ▸673 | Aug. 4, 2026 | Jill Yob, Van Buren Township Environmental Commissioner | Oppose rescission | Government / elected official | ENV |
Position: Oppose rescission (unanimous) · Entity: Government / elected official (majority) Modification posture: No modification requested — no substantive request to change the framework ENV Environmental impact / consequences — “The climate we live in is rapidly changing for the worse.” | |||||
| ▸672 | Aug. 4, 2026 | Jeffrey Kaufman | Support rescission | Individual | AUTH CAPFORM CB CBA IMMAT REDUN |
Position: Support rescission (unanimous) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework AUTH Statutory authority / major-questions (either direction) — “The Final Rules stray well beyond the policy concerns of the Federal securities laws;” CAPFORM Market efficiency / capital formation — “at odds with the Commission's policy objectives of facilitating capital formation and promoting public company status.” CB Compliance burden — “The Final Rules impose substantial costs” CBA Cost-benefit assessment — “impose substantial costs that are not justified by the informational benefits they may provide to some investors” IMMAT Immaterial / not decision-useful — “The Final Rules are unnecessary and inconsistent with a registrant-specific, materiality-based approach to disclosure;” REDUN Redundant — existing rules, materiality regime, or voluntary reporting already suffice — “inconsistent with a registrant-specific, materiality-based approach to disclosure” | |||||
| ▸671 | Aug. 4, 2026 | Frances Tauzer, Davis Farmers Market Alliance | Oppose rescission | Individual | ACCT ENV IP |
Position: Oppose rescission (unanimous) · Entity: Individual (majority) Modification posture: No modification requested — no substantive request to change the framework ACCT Stewardship / accountability — “hiding that information is harmful to everyone in the long run” ENV Environmental impact / consequences — “We cannot afford any steps backwards when it comes to environmental commitments and climate change action.” IP Investor protection / decision usefulness — “we need information provided by companies to make informed decisions” | |||||
| ▸670 | Aug. 4, 2026 | Don Andrews, Executive Director, Pension Investment Association of Canada | Duplicate | Investor / asset manager (institutional) | |
Position: Duplicate (unanimous) · Entity: Investor / asset manager (institutional) (unanimous) Modification posture: No modification requested — no substantive request to change the framework No coded rationale. | |||||
| ▸669 | Aug. 4, 2026 | Devyani Cox | Oppose rescission | Individual | Modify / Expand CAPFORM CFR CMP DEMAND IP |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: Modify / Expand — asks for stronger or broader disclosure CAPFORM Market efficiency / capital formation — “increases information asymmetry between companies and the investors who fund them, at real cost to market integrity” CFR Climate-related financial risk — “Climate risk is financial risk.” CMP Standardization / comparability — “makes it far harder to compare companies, price risk accurately, and allocate capital efficiently” DEMAND Investor demand / fund reliance — “Investors managing trillions of dollars have said for years that they need consistent, comparable, and decision-useful information” IP Investor protection / decision usefulness — “decision-useful information about how companies are exposed to and managing physical climate risks” | |||||
| ▸668 | Aug. 4, 2026 | David Vassar | Oppose rescission | Individual | ACCT CFR ENV IP |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework ACCT Stewardship / accountability — “This provision is critical to keeping companies honest about the Climate impacts of their operations and productions” CFR Climate-related financial risk — “material climate-related risks” ENV Environmental impact / consequences — “I'm a father deeply concerned over his son's prospects for a habitable world amid an increasingly volatile Climate.” IP Investor protection / decision usefulness — “provide investors with information about material climate-related risks in registration statements and annual reports” | |||||
| ▸667 | Aug. 4, 2026 | Carolyn Patten | Oppose rescission | Individual | Modify / Expand ACCT ENV PP |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: Modify / Expand — asks for stronger or broader disclosure ACCT Stewardship / accountability — “Our government has the absolute responsibility to respect the science” ENV Environmental impact / consequences — “the entire state is in severe drought and has been for months” PP Political pressure / regulatory capture — “bowing to the greed of big oil and gas” | |||||
| ▸666 | Aug. 4, 2026 | C.S. | 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 — “hold the violating companies accountable” ENV Environmental impact / consequences — “we've been plagued by nearby factories violating air quality standards” | |||||
| ▸665 | Aug. 4, 2026 | C. Malkin | 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 — “Each year, natural disasters reek havoc on communities across the country” | |||||
| ▸664 | Aug. 4, 2026 | Brian B. | 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 — “Changes to the climate affect everyone, not just stakeholders in the company making the decision.” | |||||
| ▸663 | Aug. 4, 2026 | Andrea | 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 — “Protecting environmental well-being also protects the value of investments.” ENV Environmental impact / consequences — “any additional contribution to global warming” IP Investor protection / decision usefulness — “investors alike deserve accurate and complete information to make fully-informed decisions” | |||||
| ▸662 | Aug. 4, 2026 | Alex Griffin, Retired | 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 — “People need to know the danger they face especially with the world on fire.” | |||||
| ▸661 | Aug. 4, 2026 | Abby Berk, Board Member, Emerald Keepers | Oppose rescission | Environmental / ESG advocacy org | IP |
Position: Oppose rescission (unanimous) · Entity: Environmental / ESG advocacy org (majority) Modification posture: No modification requested — no substantive request to change the framework IP Investor protection / decision usefulness — “Corporate climate disclosure is essential information for investors” | |||||
| ▸660 | Aug. 4, 2026 | Todd Snyder | Oppose rescission | Individual | CMP ENV IP |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework CMP Standardization / comparability — “make significant climate-related information more consistent, comparable, and accessible” ENV Environmental impact / consequences — “Communities would lose a critical public source of environmental data.” IP Investor protection / decision usefulness — “Investors could instead be required to locate information across general SEC filings, voluntary sustainability reports, state disclosure systems, and other company materials.” | |||||
| ▸659 | Aug. 4, 2026 | Stephanie Ragusa | Oppose rescission | Individual | Modify / Expand FRAG IP |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: Modify / Expand — asks for stronger or broader disclosure FRAG Regulatory fragmentation / multi-jurisdictional consistency — “locate information across general SEC filings, voluntary sustainability reports, state disclosure systems, and other company materials” IP Investor protection / decision usefulness — “Investors could instead be required to locate information across general SEC filings, voluntary sustainability reports, state disclosure systems, and other company materials” | |||||
| ▸658 | Aug. 4, 2026 | Richard Worth | Oppose rescission | Individual | Modify / Expand AUTH CMP ENV FRAG INSUFF IP PP |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: Modify / Expand — asks for stronger or broader disclosure AUTH Statutory authority / major-questions (either direction) — “You argue that the rules exceed your legal authority” CMP Standardization / comparability — “make significant climate-related information more consistent, comparable, and accessible” ENV Environmental impact / consequences — “Communities would lose a critical public source of environmental data.” FRAG Regulatory fragmentation / multi-jurisdictional consistency — “state disclosure systems” INSUFF Insufficient / incoherent legal basis (either direction) — “why did it take two years to realize that?” IP Investor protection / decision usefulness — “provide investors with information about climate-related risks in registration statements and annual reports” PP Political pressure / regulatory capture — “sounds like a response to lobby pressure” | |||||
| ▸657 | Aug. 4, 2026 | Richard Cornwall | No position | Individual | ENV |
Position: No position (unanimous) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework ENV Environmental impact / consequences — “We must protect our climate!” | |||||
| ▸656 | Aug. 4, 2026 | Richard A, Fortunati, Retired | 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 — “The horrible heat, the forest fires, the stronger storms and all the rest, including ice melting and rising seas, prove the changes.” | |||||
| ▸655 | Aug. 4, 2026 | Marissa Ruiz | Oppose rescission | Individual | ACCT CAPFORM CFR CMP ENV FRAG INSUFF IP |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework ACCT Stewardship / accountability — “Rescinding the rules removes a meaningful layer of public accountability at the exact moment it is most needed.” CAPFORM Market efficiency / capital formation — “which works against efficient capital formation rather than supporting it” CFR Climate-related financial risk — “how these companies identify climate risk, account for losses from severe weather, calculate emissions” CMP Standardization / comparability — “climate-specific risk in a standardized, comparable way” ENV Environmental impact / consequences — “environmental justice communities that are disproportionately exposed to climate-related harm” FRAG Regulatory fragmentation / multi-jurisdictional consistency — “inconsistent state-level systems” INSUFF Insufficient / incoherent legal basis (either direction) — “In response to the Commission's argument that the rules interfere with capital formation: the opposite is more likely true.” IP Investor protection / decision usefulness — “Investors price risk more efficiently when they have consistent, comparable data.” | |||||
| ▸654 | Aug. 4, 2026 | Marissa Ruiz | Oppose rescission | Individual | ACCT AUTH CAPFORM CB CBA CFR CMP ENV IP |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework ACCT Stewardship / accountability — “how leadership oversees it” AUTH Statutory authority / major-questions (either direction) — “the Commission's rationale that the rules exceed its authority and impose unnecessary compliance costs” CAPFORM Market efficiency / capital formation — “That is a worse outcome for capital formation and market efficiency, because it increases the cost and difficulty of accurately pricing risk.” CB Compliance burden — “impose unnecessary compliance costs” CBA Cost-benefit assessment — “That is a worse outcome for capital formation and market efficiency, because it increases the cost and difficulty of accurately pricing risk.” CFR Climate-related financial risk — “what financial exposure companies carry from severe weather, wildfire, drought, and other climate-driven events” CMP Standardization / comparability — “consistent, comparable, and accessible information about material climate risk” ENV Environmental impact / consequences — “This proposal also carries real consequences for environmental justice communities.” IP Investor protection / decision usefulness — “The 2024 rules were built to give investors consistent, comparable, and accessible information about material climate risk” | |||||
| ▸653 | Aug. 4, 2026 | Luis Miguel Valle Ramírez | Oppose rescission | Individual | ACCT 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 — “corporate transparency and environmental responsibility” ENV Environmental impact / consequences — “jeopardize the progress made in combating climate change, protecting the environment, and preserving the ozone layer” INSUFF Insufficient / incoherent legal basis (either direction) — “Economic policy should not prevail over science or the available scientific evidence” IP Investor protection / decision usefulness — “Information disclosed under the current regulatory framework allows investors, regulators, and the general public to make informed decisions” | |||||
| ▸652 | Aug. 4, 2026 | James S. Roberts | Oppose rescission | Individual | ACCT CFR ENV IP |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework ACCT Stewardship / accountability — “describe publicly announced climate targets” CFR Climate-related financial risk — “account for severe-weather losses” ENV Environmental impact / consequences — “Flint, MI., oil rigs capped are leaking West Texas, “petrochemical alley” - Louisiana, nuclear radiation, etc” IP Investor protection / decision usefulness — “Climate disclosures can help investors and the public understand how companies identify significant climate risks, account for severe-weather losses, calculate certain emissions, and describe publicly announced climate targets.” | |||||
| ▸651 | Aug. 4, 2026 | gary | No position | Individual | |
Position: No position (unanimous) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework No coded rationale. | |||||
| ▸650 | Aug. 4, 2026 | Delara Good-Mojab | 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 — “Take care of the earth and don’t let efforts to protect it leave.” | |||||
| ▸649 | Aug. 4, 2026 | Anonymous | Oppose rescission | Individual | AUTH CFR CMP DEMAND INSUFF IP |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework AUTH Statutory authority / major-questions (either direction) — “has never been limited to a fixed inventory of disclosure topics existing in 1933 or 1934” CFR Climate-related financial risk — “Credit rating agencies now incorporate climate risk directly into the credit analysis that determines the cost of capital for issuers” CMP Standardization / comparability — “had produced inconsistent, incomplete, and non-comparable climate disclosure across registrants” DEMAND Investor demand / fund reliance — “the Commission's own 2024 evidentiary findings on comparability and investor demand” INSUFF Insufficient / incoherent legal basis (either direction) — “the proposed rescission fails the reasoned-decisionmaking standard of 5 U.S.C. 553(c) and State Farm” IP Investor protection / decision usefulness — “what a reasonable investor would consider important in making an investment or voting decision” | |||||
| ▸648 | Aug. 4, 2026 | Amrita Burdick | Oppose rescission | Individual | CFR ENV IP |
Position: Oppose rescission (unanimous) · Entity: Individual (majority) Modification posture: No modification requested — no substantive request to change the framework CFR Climate-related financial risk — “climate related risks” ENV Environmental impact / consequences — “consequences of climate change” IP Investor protection / decision usefulness — “publicly traded companies need to inform investors about climate related risks” | |||||
| ▾ August 3, 2026 464 letters | |||||
| ▸709 | Aug. 3, 2026 | Richard P. Hutchison, President and General Counsel, Landmark Legal Foundation | Support rescission | Legal practitioner | AUTH CAPFORM CB CBA FRAG IMMAT INSUFF IP REDUN WHIP |
Position: Support rescission (unanimous) · Entity: Legal practitioner (unanimous) Modification posture: No modification requested — no substantive request to change the framework AUTH Statutory authority / major-questions (either direction) — “the 2024 Rules unnecessarily expand the scope of SEC’s statutory authority” CAPFORM Market efficiency / capital formation — “markets”, and “facilitate capital formation”; the disclosure rules distract from these goals” CB Compliance burden — “compile, audit, and report granular Scope 1 and Scope 2 emissions” CBA Cost-benefit assessment — “the 2024 Rules’ economic cost exceeds any foreseeable benefits” FRAG Regulatory fragmentation / multi-jurisdictional consistency — “SEC adoption of a parallel reporting regime displaces” IMMAT Immaterial / not decision-useful — “unrelated to their financial viability or performance” INSUFF Insufficient / incoherent legal basis (either direction) — “amended or repealed in their entirety by that same authority. SEC must simply ensure” IP Investor protection / decision usefulness — “The 2024 Rules do not serve the interest of investors” REDUN Redundant — existing rules, materiality regime, or voluntary reporting already suffice — “resulting in a redundant use of administrative authority” WHIP Regulatory whiplash / reliance interests / costs already incurred — “unlikely to implicate the reasonable reliance interests of” | |||||
| ▸647 | Aug. 3, 2026 | William Haegele | Oppose rescission | Individual | ENV PP |
Position: Oppose rescission (majority) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework ENV Environmental impact / consequences — “If you care about climate and related issues and want to fix things, I support you 100%” PP Political pressure / regulatory capture — “It's disgusting that ANYONE would support this vile administration focused solely on GREED and DESTRUCTION.” | |||||
| ▸646 | Aug. 3, 2026 | Vera Berrill | Oppose rescission | Individual | ENV PP |
Position: Oppose rescission (split) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework ENV Environmental impact / consequences — “protections for our lands, wildlife and ecosystems” PP Political pressure / regulatory capture — “some benefit to large corporations and corruption in our political system” | |||||
| ▸645 | Aug. 3, 2026 | Tobi Hoffman | Oppose rescission | Individual | AUTH |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework AUTH Statutory authority / major-questions (either direction) — “These are actions well within the scope of the Securities and Exchange Commission and need to be continued.” | |||||
| ▸644 | Aug. 3, 2026 | Tina Watkins | Oppose rescission | Individual | Modify / Expand AUTH CMP ENV FRAG IP |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: Modify / Expand — asks for stronger or broader disclosure AUTH Statutory authority / major-questions (either direction) — “The SEC now argues that the rules exceed its legal authority” CMP Standardization / comparability — “Rescinding the rules would eliminate a national framework intended to make significant climate-related information more consistent, comparable, and accessible.” ENV Environmental impact / consequences — “Communities would lose a critical public source of environmental data.” FRAG Regulatory fragmentation / multi-jurisdictional consistency — “Investors could instead be required to locate information across general SEC filings, voluntary sustainability reports, state disclosure systems, and other company materials.” IP Investor protection / decision usefulness — “Those rules would require publicly traded companies to provide investors with information about material climate-related risks in registration statements and annual reports.” | |||||
| ▸643 | Aug. 3, 2026 | Taylor Deibel, Retired | 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 need to leave our planet in a better place for our grandchildren and future generations!” | |||||
| ▸642 | Aug. 3, 2026 | Sherri Lebow | Oppose rescission | Individual | ACCT CAPFORM CFR CMP IP |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework ACCT Stewardship / accountability — “major step backward for financial transparency and public accountability” CAPFORM Market efficiency / capital formation — “Clear, uniform rules create a level playing field.” CFR Climate-related financial risk — “Severe weather events, transition costs, and energy impacts directly affect financial stability.” CMP Standardization / comparability — “Investors and communities require consistent, standardized, and comparable data on material climate risks.” IP Investor protection / decision usefulness — “Standardized disclosure under SEC filings ensures that investors have access to facts that directly affect long-term valuation.” | |||||
| ▸641 | Aug. 3, 2026 | Shawn I Sutton, MD, Family Physician | Oppose rescission | Individual | Modify / Expand ACCT CFR CMP ENV IP |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: Modify / Expand — asks for stronger or broader disclosure ACCT Stewardship / accountability — “need to be required to measure and report on these factors so that they can be responsible to their investors and the communities and the world that they exist within” CFR Climate-related financial risk — “Certain financial effects connected to severe weather, flooding, drought, wildfires, extreme temperatures, sea-level rise, carbon offsets, and renewable energy credits.” CMP Standardization / comparability — “make significant climate-related information more consistent, comparable, and accessible” ENV Environmental impact / consequences — “Climate change poses significant health risks around the world.” IP Investor protection / decision usefulness — “investors need information about material climate related risks in publically traded registration statements and annual reports” | |||||
| ▸640 | Aug. 3, 2026 | Sarah Gannon | Oppose rescission | Individual | ACCT IP PP |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework ACCT Stewardship / accountability — “VIOLATION of public trust” IP Investor protection / decision usefulness — “well thought out and in service to investors” PP Political pressure / regulatory capture — “political positioning or greed” | |||||
| ▸639 | Aug. 3, 2026 | Sam Hirsch | 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 the people and animals who inhabit our country should be protected and informed about climate status, trends and dangers related to chemicals” | |||||
| ▸638 | Aug. 3, 2026 | Robin Dax | Oppose rescission | Individual | Modify / Expand CFR ENV IP |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: Modify / Expand — asks for stronger or broader disclosure CFR Climate-related financial risk — “account for severe-weather losses” ENV Environmental impact / consequences — “This proposal is a critical issue for environmental justice communities.” IP Investor protection / decision usefulness — “Climate disclosures can help investors and the public understand how companies identify significant climate risks, account for severe-weather losses, calculate certain emissions, and describe publicly announced climate targets.” | |||||
| ▸637 | Aug. 3, 2026 | Rebecca K. Glass | 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 — “Rescinding these rules will have dire climate change consequences.” | |||||
| ▸636 | Aug. 3, 2026 | Rebecca Bratspies | Oppose rescission | Individual | AUTH CBA CFR IP |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework AUTH Statutory authority / major-questions (either direction) — “These disclosures fall squarely within the SEC's authority to require disclosures of material risks.” CBA Cost-benefit assessment — “the benefits of climate disclosures to investors (and the general public) far outweigh the costs to covered companies” CFR Climate-related financial risk — “climate change poses a significant financial risk for many publicly traded companies” IP Investor protection / decision usefulness — “shareholders like me that want to use this information for my own personal investment and financial decision-making” | |||||
| ▸635 | Aug. 3, 2026 | Phoenix Giffen | 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 only have this one planet and we must protect her at all cost.” | |||||
| ▸634 | Aug. 3, 2026 | Pamela M Holman | No position | Individual | ENV |
Position: No position (split) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework ENV Environmental impact / consequences — “CLIMATE CHANGE NEEDS TO BE ADDRESSED NOW” | |||||
| ▸633 | Aug. 3, 2026 | Nelson Price, Retired, Author | Oppose rescission | Individual | Modify / Expand ENV |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: Modify / Expand — asks for stronger or broader disclosure ENV Environmental impact / consequences — “If we don't stop the pollution, it will continue to warm and change living conditions, agriculture, work patterns and much more.” | |||||
| ▸632 | Aug. 3, 2026 | Nancy McGinnis | 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 — “Honesty and factual information about climate impact is a must for the future as a world.” | |||||
| ▸631 | Aug. 3, 2026 | Mary Jane DelMastro | 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 — “account for severe-weather losses” ENV Environmental impact / consequences — “This proposal is a critical issue for environmental justice communities.” IP Investor protection / decision usefulness — “Climate disclosures can help investors and the public understand how companies identify significant climate risks, account for severe-weather losses, calculate certain emissions, and describe publicly announced climate targets.” | |||||
| ▸630 | Aug. 3, 2026 | Marilyn S. | 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 — “transparent practices” | |||||
| ▸629 | Aug. 3, 2026 | Margaret Haldane | 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 — “perhaps leading to the planet we inhabit becoming inhabitable for future generations of humans and other species” | |||||
| ▸628 | Aug. 3, 2026 | M. Wolf, Retired Science Instructor | Oppose rescission | Individual | CFR ENV IP PP |
Position: Oppose rescission (unanimous) · Entity: Individual (majority) Modification posture: No modification requested — no substantive request to change the framework CFR Climate-related financial risk — “impacts of climate change on our future, our businesses and investments” ENV Environmental impact / consequences — “public health, the environment, and Americans' present and future well-being” IP Investor protection / decision usefulness — “disclose anything deleterious to investors' concerns” PP Political pressure / regulatory capture — “profiteers who have swallowed the fossil fuel industry's "kool-aid" lies and misinformation” | |||||
| ▸627 | Aug. 3, 2026 | Luke Wake, Senior Attorney, Pacific Legal Foundation | Support rescission | Legal practitioner | 1A AUTH CB IMMAT |
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) — “In compelling their speech, the Climate Rule will operate to shame companies that decline to institutionalize an anti-climate change agenda” AUTH Statutory authority / major-questions (either direction) — “unlawfully promulgated in excess of statutory authority” CB Compliance burden — “businesses across all sectors of the economy will be forced to expend time, energy, and money to prepare for compliance with an unprecedented climate disclosure regime” IMMAT Immaterial / not decision-useful — “the Commission should reaffirm that generalized climate-related information is ordinarily immaterial under the federal securities laws” | |||||
| ▸626 | Aug. 3, 2026 | Linda James | 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 — “It is crucial that businesses divulge the climate impact their work will have, so citizens can be aware of the problems they may face.” ENV Environmental impact / consequences — “we are already seeing the devastating effects that occur” | |||||
| ▸625 | Aug. 3, 2026 | Laura Georgi | Oppose rescission | Individual | Modify / Improve or Clarify AUTH CAPFORM CFR CMP FRAG INSUFF 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) — “The present administration is of the opinion that the SEC does not have the authority to require registrants to make these disclosures” CAPFORM Market efficiency / capital formation — “Information of this type is essential for proper market function, and the SEC properly has a role in requiring companies to make this information available.” CFR Climate-related financial risk — “These risks are already substantial and are likely to increase in the absence of significant global action in mitigation” CMP Standardization / comparability — “The 2024 rule sought to make these disclosures more consistent, accessible, and comparable across companies.” FRAG Regulatory fragmentation / multi-jurisdictional consistency — “Since international companies, at least, are also subject to disclosure rules in other jurisdictions in which they operate, the SEC should consider what those jurisdictions are requiring in the way of disclosures.” INSUFF Insufficient / incoherent legal basis (either direction) — “the present administration is not to be trusted on matters of law or fact” IP Investor protection / decision usefulness — “Publicly-traded companies have an obligation to investors to disclose climate-related risks.” | |||||
| ▸624 | Aug. 3, 2026 | Kathy Cott | 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 — “We need more information out there, not less. I’m not a mushroom.” | |||||
| ▸623 | Aug. 3, 2026 | Judith Staeuble | 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 — “the public has a right to know what companies are doing or not doing” ENV Environmental impact / consequences — “mitigate the effects of a changing climate” | |||||
| ▸622 | Aug. 3, 2026 | John Frederick | 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 — “financial impacts, particularly those caused by catastrophic weather and other climate change-induced disasters, are real and it is imperative for the investing public to know” ENV Environmental impact / consequences — “what measures publicly traded companies have taken to address or exacerbate climate change and related sustainability issues” IP Investor protection / decision usefulness — “Many of us have utilized these disclosures to help us make investment decisions” | |||||
| ▸621 | Aug. 3, 2026 | Jerri L Richards | Oppose rescission | Individual | ACCT IP |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework ACCT Stewardship / accountability — “corporate climate reporting and accountability” IP Investor protection / decision usefulness — “As an individual investor such corporate documentation is the only clear method I have to track effort, progress and transparency” | |||||
| ▸620 | Aug. 3, 2026 | Jeffrey Krupnick, Retired | 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 related effects are crucial to the health of our planet and the survival of the human species.” | |||||
| ▸619 | Aug. 3, 2026 | Jeff Lockhart | 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 — “This harms our environment to benefit the wealthy.” | |||||
| ▸618 | Aug. 3, 2026 | Jana Shakarian | No position | Individual | |
Position: No position (majority) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework No coded rationale. | |||||
| ▸617 | Aug. 3, 2026 | J. Nedbor | Oppose rescission | Individual | ACCT PP |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework ACCT Stewardship / accountability — “Who or what are you protecting?” PP Political pressure / regulatory capture — “Money and kickbacks won't protect anyone!” | |||||
| ▸616 | Aug. 3, 2026 | Gene Tunnell | Oppose rescission | Individual | NR |
Position: Oppose rescission (majority) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework NR No substantive rationale — “And this must not happen!” | |||||
| ▸615 | Aug. 3, 2026 | Florence Sandok | 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 — “heat, Flooding, drought, wildfires etc which are all a direct con sequenceof mClimate Changes” | |||||
| ▸614 | Aug. 3, 2026 | Ellen Brauza | Oppose rescission | Religious / faith-based org | ENV |
Position: Oppose rescission (unanimous) · Entity: Religious / faith-based org (majority) Modification posture: No modification requested — no substantive request to change the framework ENV Environmental impact / consequences — “It is downright evil to sacrifice the environment to profit motivations.” | |||||
| ▸613 | Aug. 3, 2026 | Elijah Sanchez | Oppose rescission | Individual | CAPFORM CFR CMP 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 — “Weakening these disclosure frameworks undermines market integrity and transparency.” CFR Climate-related financial risk — “Climate change is a growing source of financial risk for public companies and investors.” CMP Standardization / comparability — “Consistent, transparent, and standardized climate disclosures” IP Investor protection / decision usefulness — “Consistent, transparent, and standardized climate disclosures are vital for investors to accurately price long-term market risks and make fully informed capital allocation decisions.” | |||||
| ▸612 | Aug. 3, 2026 | Donna Selquist, Retiree | Oppose rescission | Individual | ACCT IP |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework ACCT Stewardship / accountability — “Don't make it easier for companies to skirt around their environmental responsibilities!” IP Investor protection / decision usefulness — “maintain or increase present levels of climate disclosure info/data in all corporate annual reports and investment summaries” | |||||
| ▸611 | Aug. 3, 2026 | Dirk R Nelson | Oppose rescission | Individual | ACCT PP |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework ACCT Stewardship / accountability — “Cleansing records for the sake of destructive corporatist and oligarch power so those parties can be less accountable is to poke the public's needs and well-being in the proverbial eye.” PP Political pressure / regulatory capture — “Stop capitulating to the Felonious Orange Nuisance's criminal and shallow under-cutting of our safeguards.” | |||||
| ▸610 | Aug. 3, 2026 | Diana Praus | 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 — “account for severe-weather losses, calculate certain emissions” ENV Environmental impact / consequences — “This proposal is a critical issue for environmental justice communities.” IP Investor protection / decision usefulness — “Climate disclosures can help investors and the public understand how companies identify significant climate risks” | |||||
| ▸609 | Aug. 3, 2026 | Debra Metzger | 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 — “Don’t rescind climate transparency!” | |||||
| ▸608 | Aug. 3, 2026 | Cheryl Voglesong | 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 — “Our country is ON FIRE and you're pouring gasoline on it!” | |||||
| ▸607 | Aug. 3, 2026 | Catherine Williams | Oppose rescission | Individual | ACCT CFR ENV GHG12 GOV TARGETS FINSTMT |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework Keep provisions: GHG12 (Scope 1 & 2 emissions), GOV (Governance / risk management), TARGETS (Targets / transition plan), FINSTMT (Financial-statement effects (Reg S-X Art. 14)) ACCT Stewardship / accountability — “Oversight of climate risks by company leadership;” CFR Climate-related financial risk — “Certain financial effects connected to severe weather, flooding, drought, wildfires, extreme temperatures, sea-level rise, carbon offsets, and renewable energy credits.” ENV Environmental impact / consequences — “The methodology used to calculate reported greenhouse gas emissions” | |||||
| ▸606 | Aug. 3, 2026 | Cary Hollingsorth | Oppose rescission | Individual | CMP ENV FRAG IP |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework CMP Standardization / comparability — “more consistent, comparable, and accessible” ENV Environmental impact / consequences — “Communities would lose a critical public source of environmental data.” FRAG Regulatory fragmentation / multi-jurisdictional consistency — “state disclosure systems” IP Investor protection / decision usefulness — “Investors could instead be required to locate information across general SEC filings, voluntary sustainability reports, state disclosure systems, and other company materials.” | |||||
| ▸605 | Aug. 3, 2026 | Carol P Saul | 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 — “The US is experiencing a severe climate crisis, with flooding, drought, wildfires becoming commonplace.” | |||||
| ▸604 | Aug. 3, 2026 | Anonymous | Oppose rescission | Individual | Modify / Expand ENV IP |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: Modify / Expand — asks for stronger or broader disclosure ENV Environmental impact / consequences — “communities lose a critical source of environmental data” IP Investor protection / decision usefulness — “provide investors with information about material risks in registration statements and annual reports” | |||||
| ▸603 | Aug. 3, 2026 | Anonymous | No position | Individual | ENV |
Position: No position (split) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework ENV Environmental impact / consequences — “help fight climate change” | |||||
| ▸602 | Aug. 3, 2026 | Alan Fiene, Clergyperso | Oppose rescission | Individual | Modify / Expand CMP ENV IP |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: Modify / Expand — asks for stronger or broader disclosure CMP Standardization / comparability — “We need stronger, consistent, comparable, and accessible climate related rules” ENV Environmental impact / consequences — “the absolutely devastating wildfires that are currently occurring in the US and around the world” IP Investor protection / decision usefulness — “to provide investors with information about material climate-related risks in registration statements and annual reports” | |||||
| ▸601 | Aug. 3, 2026 | Adelaide Steely | Oppose rescission | Individual | FRAG |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework FRAG Regulatory fragmentation / multi-jurisdictional consistency — “State rules are 50 different sets of rules.” | |||||
| ▸600 | Aug. 3, 2026 | Wayne R Stinson | Oppose rescission | Individual | CFR |
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 that have materially affected or are reasonably likely to materially affect the company;” | |||||
| ▸599 | Aug. 3, 2026 | Warren De Smidt | Oppose rescission | Individual | ACCT CFR ENV IP GHG12 GOV TARGETS FINSTMT |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework Keep provisions: GHG12 (Scope 1 & 2 emissions), GOV (Governance / risk management), TARGETS (Targets / transition plan), FINSTMT (Financial-statement effects (Reg S-X Art. 14)) ACCT Stewardship / accountability — “Oversight of climate risks by company leadership;” CFR Climate-related financial risk — “Certain financial effects connected to severe weather, flooding, drought, wildfires, extreme temperatures, sea-level rise, carbon offsets, and renewable energy credits.” ENV Environmental impact / consequences — “having an understanding about their impact on their communities and their lives” IP Investor protection / decision usefulness — “get a sense of the landscape when they need information in making various informed decisions about companies that they are thinking of getting involved with, either monetarily” | |||||
| ▸598 | Aug. 3, 2026 | Victor Novick | 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 — “This seems the least we can do to effect our changing climate in a positive way.” | |||||
| ▸597 | Aug. 3, 2026 | Valerie Carrick | Oppose rescission | Individual | Modify / Expand NR |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: Modify / Expand — asks for stronger or broader disclosure NR No substantive rationale — “We should be strengthening these regulations and protections not decreasing them.” | |||||
| ▸596 | Aug. 3, 2026 | Tracey Peterson | 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 need to protect the planet as is evidence from all the unusual weather conditions flooding, wildfires, earthquakes, tornados, tsunamis across the country.” | |||||
| ▸595 | Aug. 3, 2026 | Todd Olk | Oppose rescission | Individual | Modify / Expand ENV |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: Modify / Expand — asks for stronger or broader disclosure ENV Environmental impact / consequences — “This is terrible and horrible for people, for humans, for Americans, and for all US Citizens.” | |||||
| ▸594 | Aug. 3, 2026 | Todd | Oppose rescission | Individual | Modify / Expand ENV |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: Modify / Expand — asks for stronger or broader disclosure ENV Environmental impact / consequences — “Bad for humans, terrible for people, horrible for Americans, and not healthy for all US Citizens.” | |||||
| ▸593 | Aug. 3, 2026 | Tina Karlsson | Oppose rescission | Individual | ACCT AUTH ENV |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework ACCT Stewardship / accountability — “Stop the process of putting humanity at risk for the good of profit for the few.” AUTH Statutory authority / major-questions (either direction) — “who in 1933 and 1934 felt it was important to protect the health, safety and welfare of the people of the United States of America” ENV Environmental impact / consequences — “contribute to climate change that is clearly causing extreme heat and wildfires across the west and extreme changes in ocean warming” | |||||
| ▸592 | Aug. 3, 2026 | Thomas Keough, citizen | Oppose rescission | Individual | ACCT ENV |
Position: Oppose rescission (majority) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework ACCT Stewardship / accountability — “Any action to hide this only supports these deluded fools or thieves of the public welfare.” ENV Environmental impact / consequences — “Only idiots or criminals deny the fact that our climate is affected by human pollution.” | |||||
| ▸591 | Aug. 3, 2026 | Thomas Clemmer | 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 — “account for severe-weather losses” ENV Environmental impact / consequences — “This proposal is a critical issue for environmental justice communities.” IP Investor protection / decision usefulness — “Climate disclosures can help investors and the public understand how companies identify significant climate risks, account for severe-weather losses, calculate certain emissions, and describe publicly announced climate targets.” | |||||
| ▸590 | Aug. 3, 2026 | The Episcopal Church Office of Government Relations | Oppose rescission | Investor / asset manager (institutional) | ACCT CFR CMP DEMAND FRAG 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 — “We understand this to be a core aspect of our fiduciary duty as investors.” CFR Climate-related financial risk — “we have asked companies to report on financial risks resulting from climate change and their impact on shareholder value” CMP Standardization / comparability — “Rescinding the rules would reduce the availability of consistent, reliable, and comparable information.” DEMAND Investor demand / fund reliance — “a review of comments from 320 institutional investors that collectively own or manage over $50 trillion in assets revealed 97% of these investors supported climate risk disclosure requirements” FRAG Regulatory fragmentation / multi-jurisdictional consistency — “Global reporting has been moving toward similar climate disclosure requirements through standard-setting organizations like ISSB and GRI.” IP Investor protection / decision usefulness — “Investors like us see the incredible value that comes from climate disclosures, helping us make responsible decisions with our investments with access to as much information as possible” | |||||
| ▸589 | Aug. 3, 2026 | Tawny Reynolds, Owner, Sundrop Jewelry | Oppose rescission | Individual | Modify / Expand CFR ENV IP |
Position: Oppose rescission (unanimous) · Entity: Individual (majority) Modification posture: Modify / Expand — asks for stronger or broader disclosure CFR Climate-related financial risk — “how a company considers particular risks, such as heat domes, floods, wildfires, and more, which are becoming more prevalent in recent years” ENV Environmental impact / consequences — “such as heat domes, floods, wildfires, and more, which are becoming more prevalent in recent years” IP Investor protection / decision usefulness — “These disclosure rules help investors and the public understand how a company considers particular risks” | |||||
| ▸588 | Aug. 3, 2026 | Suzanne Duscha | 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 are facing multi-crises caused by global warning.” | |||||
| ▸587 | Aug. 3, 2026 | Stacy Rauch | 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 — “Why would I chose to invest in a company building a data center, which requires lots of water, in a place like Arizona, who doesn’t even have enough water for its people?” ENV Environmental impact / consequences — “Climate change is real.” IP Investor protection / decision usefulness — “I invest in companies that take their responsibility to our planet seriously, and want that information at the fingertips (annual reports) when researching whether to buy their stock.” | |||||
| ▸586 | Aug. 3, 2026 | Sonia Vazquez | Oppose rescission | Individual | Modify / Expand CFR CMP ENV IP |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: Modify / Expand — asks for stronger or broader disclosure CFR Climate-related financial risk — “account for severe-weather losses” CMP Standardization / comparability — “make significant climate-related information more consistent, comparable, and accessible” ENV Environmental impact / consequences — “Communities would lose a critical public source of environmental data.” IP Investor protection / decision usefulness — “Climate disclosures can help investors and the public understand how companies identify significant climate risks, account for severe-weather losses, calculate certain emissions, and describe publicly announced climate targets.” | |||||
| ▸585 | Aug. 3, 2026 | Shishpal Rawat | Oppose rescission | Individual | ACCT CFR 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 cannot allow these public companies to act in an opaque way that drives up their profits at the risk of harming the public at large.” CFR Climate-related financial risk — “account for severe-weather losses” ENV Environmental impact / consequences — “at the risk of harming the public at large” IP Investor protection / decision usefulness — “Climate disclosures can help investors and the public understand how companies identify significant climate risks, account for severe-weather losses, calculate certain emissions, and describe publicly announced climate targets.” | |||||
| ▸584 | Aug. 3, 2026 | Sheri Kapust | Oppose rescission | Individual | CFR ENV |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework CFR Climate-related financial risk — “This has an impact on our health and safety as well as a huge financial cost.” ENV Environmental impact / consequences — “The devastating impact of climate change is impossible to ignore and it is getting worse all the time.” | |||||
| ▸583 | Aug. 3, 2026 | Sharon Paltin, MD, Family Physician | 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 — “The purpose of good governmental rules is to support the common good over the greed inherent in unregulated corporate business.” ENV Environmental impact / consequences — “Our grandchildren and all future generations are counting on us not to ignore the crisis.” IP Investor protection / decision usefulness — “We consumers and investors need to be able to choose what to buy and what to invest in, in this critical time of changing climate.” | |||||
| ▸582 | Aug. 3, 2026 | SDC Enerserve, SPE | No position | Issuer / Corporate — current | IP |
Position: No position (split) · Entity: Issuer / Corporate — current (majority) Modification posture: No modification requested — no substantive request to change the framework IP Investor protection / decision usefulness — “provide investors with information about material climate-related risks in registration statements and annual reports” | |||||
| ▸581 | Aug. 3, 2026 | Sara E. Murphy, Director of System-Level Investing, Sierra Club Foundation | Oppose rescission | Environmental / ESG advocacy org | Fallback / Compromise ACCT CAPFORM CBA CFR CMP DEMAND FRAG INSUFF IP GHG12 GOV TARGETS FINSTMT |
Position: Oppose rescission (unanimous) · Entity: Environmental / ESG advocacy org (majority) 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), TARGETS (Targets / transition plan), FINSTMT (Financial-statement effects (Reg S-X Art. 14)) ACCT Stewardship / accountability — “stewardship, proxy voting, and engagement with companies and market intermediaries” CAPFORM Market efficiency / capital formation — “impair the fair and efficient functioning of U.S. capital markets” CBA Cost-benefit assessment — “The Commission’s own economic analysis anticipates that rescission would reduce the availability and reliability of climate-related information and increase investor search and verification costs.” CFR Climate-related financial risk — “climate change is both an issuer-level financial risk and a systemic risk” CMP Standardization / comparability — “Standardized requirements do not displace company-specific materiality judgments; they give registrants a common architecture within which to make and explain those judgments.” DEMAND Investor demand / fund reliance — “The rulemaking record demonstrates broad, sustained investor demand for standardized climate-related disclosure.” FRAG Regulatory fragmentation / multi-jurisdictional consistency — “leaving issuers to navigate a fragmented landscape” INSUFF Insufficient / incoherent legal basis (either direction) — “Full rescission is disproportionate, disregards the extensive investor record, and needlessly sacrifices the investor-protection benefits of the rule as a whole.” IP Investor protection / decision usefulness — “Climate disclosure is decision-useful to mainstream investors and material for many registrants.” | |||||
| ▸580 | Aug. 3, 2026 | Sam G. Yoder, Fellowship of Hope Mennonite Church | Oppose rescission | Individual | ENV PP |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework ENV Environmental impact / consequences — “The climate crisis is real and pervasive-note the current wildfires and extreme temperatures across our world.” PP Political pressure / regulatory capture — “rescinding the dissemination of climate information is a clear attempt to silence awareness and action to curtail fossil fuel use/sales” | |||||
| ▸579 | Aug. 3, 2026 | Linda Roles | 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 — “We have done way too little in the past and are paying the price. Too much of the damage is irreversible!!!” | |||||
| ▸578 | Aug. 3, 2026 | Ronald Brown | 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 — “account for severe-weather losses” ENV Environmental impact / consequences — “This proposal is a critical issue for environmental justice communities.” IP Investor protection / decision usefulness — “Climate disclosures can help investors and the public understand how companies identify significant climate risks, account for severe-weather losses, calculate certain emissions, and describe publicly announced climate targets.” | |||||
| ▸577 | Aug. 3, 2026 | Ronald Brown | Duplicate | Individual | |
Position: Duplicate (unanimous) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework No coded rationale. | |||||
| ▸576 | Aug. 3, 2026 | Robert Brown | 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 — “Rescinding the rules will lead to harmful implications, nationwide.” ENV Environmental impact / consequences — “This proposal is a critical issue for environmental justice communities.” IP Investor protection / decision usefulness — “Climate disclosures can help investors and the public understand how companies identify significant climate risks, account for severe-weather losses, calculate certain emissions, and describe publicly announced climate targets.” | |||||
| ▸575 | Aug. 3, 2026 | Richard J Ramirez | 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 — “how it affects the conditions of any transaction” ENV Environmental impact / consequences — “Climate changes affect us all.” IP Investor protection / decision usefulness — “how it affects the conditions of any transaction the more transparent the process” | |||||
| ▸574 | Aug. 3, 2026 | Ralph P Tucci | 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 — “To ensure public safety, retain the 2024 Climate Disclosure Rules.” | |||||
| ▸573 | Aug. 3, 2026 | Peggy Sands | 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 — “This is a risk we can’t afford to take.” ENV Environmental impact / consequences — “Rescinding the rules will lead to harmful implications, nationwide.” IP Investor protection / decision usefulness — “Climate disclosures can help investors and the public understand how companies identify significant climate risks, account for severe-weather losses, calculate certain emissions, and describe publicly announced climate targets.” | |||||
| ▸572 | Aug. 3, 2026 | Patricia Hall | 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 — “account for severe-weather losses” ENV Environmental impact / consequences — “This proposal is a critical issue for environmental justice communities.” IP Investor protection / decision usefulness — “Climate disclosures can help investors and the public understand how companies identify significant climate risks, account for severe-weather losses, calculate certain emissions, and describe publicly announced climate targets” | |||||
| ▸571 | Aug. 3, 2026 | Nelson Bock | 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 — “so they can protect their investments from negative impacts” ENV Environmental impact / consequences — “how a corporation's business may contribute to climate change” IP Investor protection / decision usefulness — “Investors need and deserve to know how a corporation's business may contribute to climate change or may be adversely impacted by climate change” | |||||
| ▸570 | Aug. 3, 2026 | Miriam Harlan | 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 — “account for severe-weather losses” ENV Environmental impact / consequences — “This proposal is a critical issue for environmental justice communities.” IP Investor protection / decision usefulness — “Climate disclosures can help investors and the public understand how companies identify significant climate risks, account for severe-weather losses, calculate certain emissions, and describe publicly announced climate targets.” | |||||
| ▸569 | Aug. 3, 2026 | Mira Wiegmann | 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 change will cause destructive storms, floods, and droughts that will greatly impact all businesses now and in the near future” IP Investor protection / decision usefulness — “It would be irresponsible not to make potential stock buyers aware of how these realities may affect the profitability of an investment.” | |||||
| ▸568 | Aug. 3, 2026 | Michele Springsteen | Oppose rescission | Individual | CFR ENV IP |
Position: Oppose rescission (majority) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework CFR Climate-related financial risk — “account for severe-weather losses” ENV Environmental impact / consequences — “This proposal is a critical issue for environmental justice communities.” IP Investor protection / decision usefulness — “Climate disclosures can help investors and the public understand how companies identify significant climate risks, account for severe-weather losses, calculate certain emissions, and describe publicly announced climate targets.” | |||||
| ▸567 | Aug. 3, 2026 | Michael Lester | 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 — “Do not change the climate rules on S7-2026-19” | |||||
| ▸566 | Aug. 3, 2026 | Michael Cynamon | 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 — “Climate related disclosure rules should remain intact” | |||||
| ▸565 | Aug. 3, 2026 | Merry Kimble | Oppose rescission | Individual | Modify / Expand ENV |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: Modify / Expand — asks for stronger or broader disclosure ENV Environmental impact / consequences — “In this time of rapid planetary heating, we need accurate climate information disclosure for everyone.” | |||||
| ▸564 | Aug. 3, 2026 | Meg 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 — “It’s necessary to continue climate-affecting disclosure rules for companies.” | |||||
| ▸563 | Aug. 3, 2026 | Mary Riddle | Oppose rescission | Individual | Modify / Expand ENV |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: Modify / Expand — asks for stronger or broader disclosure ENV Environmental impact / consequences — “Rescinding the rules will lead to harmful implications nationwide and this is already evidenced by LEAD in our groundwater!” | |||||
| ▸562 | Aug. 3, 2026 | Mark Spinner | 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 — “the US and the world are suffering from severe droughts extreme and more fires flooding more and severe weather” | |||||
| ▸561 | Aug. 3, 2026 | Maria Chansky | Oppose rescission | Individual | Modify / Expand ENV |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: Modify / Expand — asks for stronger or broader disclosure ENV Environmental impact / consequences — “Each day I see many patients with heart disease, lung disease, mental health concerns and nutritional issues that are impacted by climate change.” | |||||
| ▸560 | Aug. 3, 2026 | Mari Peralta | 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 — “If I invest in a REIT holding properties along a coastline that is very vulnerable to hurricanes and sea level rise, I need to be able to evaluate that risk.” IP Investor protection / decision usefulness — “As an individual investor, it’s essential for me to be able to evaluate a company’s risk exposure.” | |||||
| ▸559 | Aug. 3, 2026 | Madeline J. Lee, Juris doctorate of Law | Oppose rescission | Individual | PP |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework PP Political pressure / regulatory capture — “The only thing that has changed is the political pressure you are being subjected to in order to protect the fossil fuel industry.” | |||||
| ▸558 | Aug. 3, 2026 | Lynn Redmon | 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 — “I OPPOSE your File Number S7-2026-19 proposal.” | |||||
| ▸557 | Aug. 3, 2026 | Lois Ebey | 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 — “I believe that Climate Disclosures are critical now and for the future because they communicate the risks that projects may pose.” ENV Environmental impact / consequences — “that person deserves to know the details of what may be impacting their air, ground and water.” | |||||
| ▸556 | Aug. 3, 2026 | Linda J Stock | Oppose rescission | Individual | CBA ENV |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework CBA Cost-benefit assessment — “We need to show what the consequences of building are going to be so that it can be fairly evaluated as benefits versus negative effects.” ENV Environmental impact / consequences — “Climate change is proceeding at a ferocious pace, causing death and destruction.” | |||||
| ▸555 | Aug. 3, 2026 | Linda Golley | 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 — “Please do everything in your power to maintain tracking, documentation, and reporting of climate-threatening emissions.” ENV Environmental impact / consequences — “Climate change is real, it is dangerous to every living being on earth, including Republicans who pretend that it does not exist.” | |||||
| ▸554 | Aug. 3, 2026 | Linda Golley | Duplicate | Individual | |
Position: Duplicate (unanimous) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework No coded rationale. | |||||
| ▸553 | Aug. 3, 2026 | Larry Russell, Professor of Oral Interpretation | Oppose rescission | Individual | NR |
Position: Oppose rescission (unanimous) · Entity: Individual (majority) Modification posture: No modification requested — no substantive request to change the framework NR No substantive rationale — “Please do not rescind those laws/rules. We need them.” | |||||
| ▸552 | Aug. 3, 2026 | Kenneth Powers | No position | Individual | |
Position: No position (unanimous) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework No coded rationale. | |||||
| ▸551 | Aug. 3, 2026 | Ken Wooley | 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 — “We would lose a critical public source of environmental data.” IP Investor protection / decision usefulness — “As a small investor, I would instead have to try to dig out information across general SEC filings, voluntary sustainability reports, state disclosure systems, and other company materials.” | |||||
| ▸550 | Aug. 3, 2026 | Kathryn Dorn | Oppose rescission | Individual | Modify / Expand CFR ENV IP PP |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: Modify / Expand — asks for stronger or broader disclosure CFR Climate-related financial risk — “allow companies to hide their real, portfolio-endangeing exposure to the consequenes of climate-change-exacerbated storms, floods, fires, disease, water scarcity, and temperature extremes” ENV Environmental impact / consequences — “myriad business-threatening disasters are growing more frequent and more severe as a result” IP Investor protection / decision usefulness — “Please do not jeopardize investors' financial health and self-detemination by depriving them of theital information provided by climate-risk disclosures!” PP Political pressure / regulatory capture — “no one but an oil-company CEO would ultimately thank the SEC if you finalize this rule” | |||||
| ▸549 | Aug. 3, 2026 | Katherine Carter | 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 — “Our planet is burning and it is important to protect our environment!!” | |||||
| ▸548 | Aug. 3, 2026 | Kate Roth | 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 — “Do not rescind climate information or protection!” | |||||
| ▸547 | Aug. 3, 2026 | Julie Bernstein | Oppose rescission | Individual | ACCT CFR ENV IP |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework ACCT Stewardship / accountability — “invest in companies that take on the responsibility for reducing their own climate footprint” CFR Climate-related financial risk — “Businesses small and large are being impacted whether as a result of the destruction of local headquarters, interruption to sourcing of components or disruptions of logistics.” ENV Environmental impact / consequences — “We are witnessing the impact of climate-fueled fires, such as the latest one in Spokane, Washington” IP Investor protection / decision usefulness — “As someone who invests in businesses, I would like to know what companies are doing to mitigate their individual risks” | |||||
| ▸546 | Aug. 3, 2026 | Julianne Banks, IT Consultant | 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 — “This is a ridiculous proposition to roll back transparency on climate issues.” | |||||
| ▸545 | Aug. 3, 2026 | Judith Lindquist, Teacher | Oppose rescission | Individual | Modify / Expand ENV |
Position: Oppose rescission (unanimous) · Entity: Individual (majority) Modification posture: Modify / Expand — asks for stronger or broader disclosure ENV Environmental impact / consequences — “Climate change and pollution are serious problems to be solved.” | |||||
| ▸544 | Aug. 3, 2026 | Juan Carlos Latorre | Oppose rescission | Individual | DEMAND ENV FRAG |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework DEMAND Investor demand / fund reliance — “Investors, customers, and international regulators are increasingly demanding comprehensive emissions reporting.” ENV Environmental impact / consequences — “would accelerate the greenhouse effect, global warming, and climate change” FRAG Regulatory fragmentation / multi-jurisdictional consistency — “align with international best practices” | |||||
| ▸543 | Aug. 3, 2026 | Joseph Bernard Cadotte | Oppose rescission | Individual | Modify / Expand ACCT ENV |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: Modify / Expand — asks for stronger or broader disclosure ACCT Stewardship / accountability — “This information must be public to allow any corporations to be held accountable for their environmental cost.” ENV Environmental impact / consequences — “environmental cost” | |||||
| ▸542 | Aug. 3, 2026 | Jose | Oppose rescission | Individual | PP |
Position: Oppose rescission (majority) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework PP Political pressure / regulatory capture — “Do the right thing and don’t bow down to corporate greed!” | |||||
| ▸541 | Aug. 3, 2026 | Jon Reisdorf | Oppose rescission | Individual | Modify / Expand ACCT ENV |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: Modify / Expand — asks for stronger or broader disclosure ACCT Stewardship / accountability — “aids in making fully informed decisions by government agencies responsible for enforcement of existing laws” ENV Environmental impact / consequences — “Huge intense fires, floods, and ever more deadly tornadoes and hurricanes happen not every 100 years but yearly” | |||||
| ▸540 | Aug. 3, 2026 | John Wondzell | Oppose rescission | Individual | Modify / Expand ENV |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: Modify / Expand — asks for stronger or broader disclosure ENV Environmental impact / consequences — “Rescinding the rules will lead to harmful implications, nationwide.” | |||||
| ▸539 | Aug. 3, 2026 | John R Carter, College professor, Fortune 500 Executive | No position | Individual | |
Position: No position (unanimous) · Entity: Individual (majority) Modification posture: No modification requested — no substantive request to change the framework No coded rationale. | |||||
| ▸538 | Aug. 3, 2026 | John Hennessy | 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 — “identify significant climate risks” ENV Environmental impact / consequences — “This proposal is a critical issue for environmental justice communities” IP Investor protection / decision usefulness — “Climate disclosures can help investors and the public understand how companies identify significant climate risks” | |||||
| ▸537 | Aug. 3, 2026 | Jeff S. Green | 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 — “The present rules of transparency are excellent and should stand.” | |||||
| ▸536 | Aug. 3, 2026 | Jayne Carter | Oppose rescission | Individual | Modify / Expand CFR ENV IP |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: Modify / Expand — asks for stronger or broader disclosure CFR Climate-related financial risk — “identify significant climate risks” ENV Environmental impact / consequences — “This proposal is a critical issue for environmental justice communities” IP Investor protection / decision usefulness — “Climate disclosures can help investors and the public understand how companies identify significant climate risks” | |||||
| ▸535 | Aug. 3, 2026 | J.C. West | Oppose rescission | Individual | Modify / Expand CFR ENV IP |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: Modify / Expand — asks for stronger or broader disclosure CFR Climate-related financial risk — “identify significant climate risks” ENV Environmental impact / consequences — “Rescinding the rules will lead to harmful implications, nationwide.” IP Investor protection / decision usefulness — “Climate disclosures can help investors and the public understand how companies identify significant climate risks” | |||||
| ▸534 | Aug. 3, 2026 | Holly Nahar / AJF Capital Management | Oppose rescission | Investor / asset manager (institutional) | ACCT CFR 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 — “the companies with the most to hide have the least incentive to disclose it” CFR Climate-related financial risk — “physical risks to companies have increased” IP Investor protection / decision usefulness — “investors cannot price a risk they cannot see” | |||||
| ▸533 | Aug. 3, 2026 | Herb Caesar | 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 — “Don't change SEC rules !!” | |||||
| ▸532 | Aug. 3, 2026 | Glenn Messina | Oppose rescission | Individual | CFR CMP 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 — “identify significant climate risks” CMP Standardization / comparability — “Rescinding the rules would eliminate a national framework intended to make significant climate-related information more consistent, comparable, and accessible.” ENV Environmental impact / consequences — “Communities would lose a critical public source of environmental data.” IP Investor protection / decision usefulness — “Investors could instead be required to locate information across general SEC filings, voluntary sustainability reports, state disclosure systems, and other company materials.” | |||||
| ▸531 | Aug. 3, 2026 | Gideon Yuval | 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 — “Whatever the merit of the climate issue, facts should be public.” | |||||
| ▸530 | Aug. 3, 2026 | Gerard Rohlf, Retired Parish Music Minister | Oppose rescission | Individual | ACCT IP |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework ACCT Stewardship / accountability — “The result amounts to a return to the old "smokey Backroom" - Home of secret shady deals by shifty, irresponsible Shysters.” IP Investor protection / decision usefulness — “Rescinding Climate Disclosure Rules simply closes a Door to the Public whose Investments keep that Company afloat.” | |||||
| ▸529 | Aug. 3, 2026 | Gentry Collins, Chief Executive Officer, The American Free Enterprise Chamber of Commerce | Support rescission | Business trade association / advocacy org | Modify / Reduce 1A AUTH CB CBA CFR DEMAND FRAG IMMAT IP PP REDUN |
Position: Support rescission (unanimous) · Entity: Business trade association / advocacy org (unanimous) Modification posture: Modify / Reduce — asks for fewer or more limited requirements 1A Compelled speech / First Amendment (either direction) — “the 2024 Rules compel registrants to engage in controversial speech in violation of the First Amendment” AUTH Statutory authority / major-questions (either direction) — “were a dramatic overreach of the Commission’s statutory authority and … unsound as a matter of policy” CB Compliance burden — “shift the costs and burdens of researching and reviewing non-material information to public investors generally” CBA Cost-benefit assessment — “it has weighed the costs and benefits of compelling non-material climate-related disclosures and affirmatively determined that registrants should not be required to make them” CFR Climate-related financial risk — “a legally compelled or consumer-driven transition away
from carbon-intensive products, is inevitable” DEMAND Investor demand / fund reliance — “The Commission premised the 2024 Rules on “respond[ing] to the growing investor need for more reliable information regarding climate-related risks.”” FRAG Regulatory fragmentation / multi-jurisdictional consistency — “California has adopted SB 253, the Climate Corporate Data Accountability Act, mandating disclosure of Scope 1, 2, and 3 emissions, and SB 261, mandating disclosure of climate-related financial risks.” IMMAT Immaterial / not decision-useful — “reached well beyond what a reasonable investor would consider important in buying and selling securities” IP Investor protection / decision usefulness — “advocating for securities regulations that serve to protect investors, not as a backdoor vehicle for an ideological agenda” PP Political pressure / regulatory capture — “were the product of the divisive and politicized chairmanship of Gary Gensler, who sought to unlawfully expand the Commission’s authority in unprecedented ways” REDUN Redundant — existing rules, materiality regime, or voluntary reporting already suffice — “the U.S. Environmental Protection Agency’s (“EPA”) GHG reporting program provides all the information on companies’ GHG emissions that any investor could need” | |||||
| ▸528 | Aug. 3, 2026 | Gary Towne | 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 — “Don't make the crisis worse.” | |||||
| ▸527 | Aug. 3, 2026 | Gary Ivey | 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 — “That action will have a negative impact on humans.” | |||||
| ▸526 | Aug. 3, 2026 | Gale Turner Strong | Oppose rescission | Individual | Modify / Expand ACCT |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: Modify / Expand — asks for stronger or broader disclosure ACCT Stewardship / accountability — “Think about the public, not big corporations!” | |||||
| ▸525 | Aug. 3, 2026 | Gail Fleischaker | Oppose rescission | Individual | Modify / Expand CFR CMP ENV |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: Modify / Expand — asks for stronger or broader disclosure CFR Climate-related financial risk — “Companies must continue to identify and manage climate-related risks, maintaining oversight of climate risks that materially affect the company” CMP Standardization / comparability — “Rescinding the rules would eliminate a national framework intended to make significant climate-related information more consistent, comparable, and accessible.” ENV Environmental impact / consequences — “Communities would lose a critical public source of environmental data.” | |||||
| ▸524 | Aug. 3, 2026 | Fran Hickey | 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 — “the SEC should be protecting the citizens of the US not enable businesses to skitter away” ENV Environmental impact / consequences — “Climate change due to fossil fuels is an existential crisis” | |||||
| ▸523 | Aug. 3, 2026 | Farid Watson | 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 — “Don't hide possible Environmental Impact dangers.” | |||||
| ▸522 | Aug. 3, 2026 | Esther David | Oppose rescission | Individual | Modify / Expand CFR ENV IP |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: Modify / Expand — asks for stronger or broader disclosure CFR Climate-related financial risk — “identify significant climate risks” ENV Environmental impact / consequences — “This proposal is a critical issue for environmental justice communities.” IP Investor protection / decision usefulness — “Climate disclosures can help investors and the public understand how companies identify significant climate risks, account for severe-weather losses, calculate certain emissions, and describe publicly announced climate targets.” | |||||
| ▸521 | Aug. 3, 2026 | Erin Staudt | Oppose rescission | Individual | Modify / Expand CFR ENV IP |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: Modify / Expand — asks for stronger or broader disclosure CFR Climate-related financial risk — “identify significant climate risks” ENV Environmental impact / consequences — “We are all affected by environmental challenges and need to be informed.” IP Investor protection / decision usefulness — “Climate disclosures can help investors and the public understand how companies identify significant climate risks” | |||||
| ▸520 | Aug. 3, 2026 | Ellen Glaccum | 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 — “Please don’t rescind the 2024 SEC climate related disclosure rules.” | |||||
| ▸519 | Aug. 3, 2026 | Elia Saez | Oppose rescission | Individual | ACCT IP |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework ACCT Stewardship / accountability — “Don’t let corporations get away with hiding these important disclosures to their shareholders and consumers.” IP Investor protection / decision usefulness — “important disclosures to their shareholders and consumers” | |||||
| ▸518 | Aug. 3, 2026 | EJ Northrop | Oppose rescission | Individual | CBA ENV IP |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework CBA Cost-benefit assessment — “cost more the longer we wait to reign in their use” ENV Environmental impact / consequences — “We find ourselves almost constantly facing OLD AND NEW threats to the safety and integrity of our environment.” IP Investor protection / decision usefulness — “minimal benefit to ordinary investors. We still need to know what's being used.” | |||||
| ▸517 | Aug. 3, 2026 | Donna Turman | 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 — “The world is literally on fire and we are losing ways to manage it every day.” | |||||
| ▸516 | Aug. 3, 2026 | Deven Burns | 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 — “Do not get rid of the climate-related disclosure rules.” | |||||
| ▸515 | Aug. 3, 2026 | Dennis Ahearn | 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 — “our awareness and commitment to our environment and our climate” | |||||
| ▸514 | Aug. 3, 2026 | Delia Wallin-Gill | 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 — “hide how companies are polluting our world for profit” ENV Environmental impact / consequences — “polluting our world for profit” | |||||
| ▸513 | Aug. 3, 2026 | Debbie hagstrom | Oppose rescission | Individual | NR |
Position: Oppose rescission (majority) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework NR No substantive rationale — “YOU ARE LIKE BIRDS BURYING YOUR HEADS IN THE SAND !” | |||||
| ▸512 | Aug. 3, 2026 | David warrender, Retired | 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 — “Our climate is failing, we must do all we can to protect it.” | |||||
| ▸511 | Aug. 3, 2026 | David Pinno | 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 just had a deadly tornado in Wisconsin” | |||||
| ▸510 | Aug. 3, 2026 | Colin Vettier | Oppose rescission | Individual | Modify / Expand ACCT CFR CMP ENV IP |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: Modify / Expand — asks for stronger or broader disclosure ACCT Stewardship / accountability — “Stronger rules to hold polluters accountable, not less rules.” CFR Climate-related financial risk — “identify significant climate risks” CMP Standardization / comparability — “make significant climate-related information more consistent, comparable, and accessible” ENV Environmental impact / consequences — “Communities would lose a critical public source of environmental data.” IP Investor protection / decision usefulness — “Investors could instead be required to locate information across general SEC filings, voluntary sustainability reports, state disclosure systems, and other company materials.” | |||||
| ▸509 | Aug. 3, 2026 | Claude Duss, Retired CEO | Oppose rescission | Individual | CFR IP |
Position: Oppose rescission (unanimous) · Entity: Individual (majority) Modification posture: No modification requested — no substantive request to change the framework CFR Climate-related financial risk — “We all need to understand the climate related impact and potential liabilities of companies reporting in which we are shareholders or potential investors” IP Investor protection / decision usefulness — “We all need to understand the climate related impact and potential liabilities of companies reporting in which we are shareholders or potential investors” | |||||
| ▸508 | Aug. 3, 2026 | Cindi Darling | Oppose rescission | Individual | Modify / Expand CMP ENV IP |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: Modify / Expand — asks for stronger or broader disclosure CMP Standardization / comparability — “more consistent, comparable, and accessible to investors and potentially impacted communities” ENV Environmental impact / consequences — “climate changes impacting our environment” IP Investor protection / decision usefulness — “accessible to investors and potentially impacted communities” | |||||
| ▸507 | Aug. 3, 2026 | Chris Melograna | 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 — “more consistent, comparable, and accessible” FRAG Regulatory fragmentation / multi-jurisdictional consistency — “state disclosure systems” IP Investor protection / decision usefulness — “Investors would instead be required to locate information across general SEC filings, voluntary sustainability reports, state disclosure systems, and other company materials.” | |||||
| ▸506 | Aug. 3, 2026 | Cheryl Herr-Rains, Retired teacher | Oppose rescission | Individual | Modify / Expand CFR CMP FRAG IP |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: Modify / Expand — asks for stronger or broader disclosure CFR Climate-related financial risk — “provide investors with information about material climate-related risks in registration statements and annual reports” CMP Standardization / comparability — “more consistent, comparable, and accessible” FRAG Regulatory fragmentation / multi-jurisdictional consistency — “state disclosure systems” IP Investor protection / decision usefulness — “provide investors with information about material climate-related risks in registration statements and annual reports” | |||||
| ▸505 | Aug. 3, 2026 | Charles W Baumann | 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 — “They need to be held accountable to all of their stakeholders that they are being good stewards to our planet.” ENV Environmental impact / consequences — “The public deserves to know what businesses are discharging into our air, water, and soils.” | |||||
| ▸504 | Aug. 3, 2026 | Celeste C Hong | 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 — “make significant climate-related information more consistent, comparable, and accessible” FRAG Regulatory fragmentation / multi-jurisdictional consistency — “state disclosure systems” IP Investor protection / decision usefulness — “Investors could instead be required to locate information across general SEC filings, voluntary sustainability reports, state disclosure systems, and other company materials.” | |||||
| ▸503 | Aug. 3, 2026 | Carol Fleischman | Oppose rescission | Individual | Modify / Expand CAPFORM CFR |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: Modify / Expand — asks for stronger or broader disclosure CAPFORM Market efficiency / capital formation — “Climate change will have an impact on the stock market, as it has indeed already impacted many sectors of the U.S. economy.” CFR Climate-related financial risk — “Climate change has an enormous potential to cause economic disruption.” | |||||
| ▸502 | Aug. 3, 2026 | C. Alexander Cohen | 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 — “It is short-sighted and downright dangerous to investors’ portfolios to ignore the dangers of climate change” ENV Environmental impact / consequences — “From every year’s breaking of heat records and wildfires spreading to an unbelievable extent we can see this IS climate change and the damage is extensive and expensive.” IP Investor protection / decision usefulness — “If this isn’t of concern to investors and corporations, I don’t know what is.” | |||||
| ▸501 | Aug. 3, 2026 | Brye Myles | 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 — “account for severe-weather losses” ENV Environmental impact / consequences — “This proposal is a critical issue for environmental justice communities.” IP Investor protection / decision usefulness — “Climate disclosures can help investors and the public understand how companies identify significant climate risks” | |||||
| ▸500 | Aug. 3, 2026 | Brian Higgins | 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 — “Do not rescind the 2024 regulation requiring full ecological disclosure.” | |||||
| ▸499 | Aug. 3, 2026 | Brian Erenstone | 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 — “Rescinding the climate disclosure rules will lead to harmful implications, nationwide.” | |||||
| ▸498 | Aug. 3, 2026 | Bob Schildgen | 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 — “Climate disclosure rules are designed to protect us. They must NOT be weakened in any way,” | |||||
| ▸497 | Aug. 3, 2026 | Beth Goode | 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 wreaking havoc on the planet and rescinding the amendments under the Securities Act of 1933 and Securities Exchange Act of 1934 will only make thing worse.” | |||||
| ▸496 | Aug. 3, 2026 | Barbara Smith | 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 must take responsibility for their destruction actions.” ENV Environmental impact / consequences — “The deadly heat waves, fires, and droughts are all symptoms of climate change which in turn is caused by human actions.” | |||||
| ▸495 | Aug. 3, 2026 | Barbara Diederichs | 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 — “information about material climate-related risks in registration statements and annual reports” IP Investor protection / decision usefulness — “this information is absolutely essential when I make investment choices” | |||||
| ▸494 | Aug. 3, 2026 | Barbara Adler | 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 — “It is important information that needs to be had.” | |||||
| ▸493 | Aug. 3, 2026 | Anonymous | Oppose rescission | Individual | Modify / Expand CFR IP |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: Modify / Expand — asks for stronger or broader disclosure CFR Climate-related financial risk — “climate-related risks will affect their investments that are tied to their retirement accounts” IP Investor protection / decision usefulness — “Individual investors like the American working class who have 401(k), IRA, and savings in the stock market deserve to have transparency about climate-related risks” | |||||
| ▸492 | Aug. 3, 2026 | Anonymous | 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 — “understand how companies identify significant climate risks” ENV Environmental impact / consequences — “Rescinding the rules will lead to harmful implications, nationwide.” IP Investor protection / decision usefulness — “Climate disclosures can help investors and the public understand how companies identify significant climate risks, account for severe-weather losses, calculate certain emissions, and describe publicly announced climate targets.” | |||||
| ▸491 | Aug. 3, 2026 | Andrew Hefner | 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 — “will reduce or eliminate the information required by conscientious investors to make informed financial decisions” | |||||
| ▸490 | Aug. 3, 2026 | Andrew Friedman, AJF Capital Management Inc., registered Investment Advisor | Oppose rescission | Investor / asset manager (institutional) | CFR CMP DEMAND 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 — “Climate-related risks and opportunities are increasingly material to many companies’ long-term performance.” CMP Standardization / comparability — “it simply provides investors with relevant, comparable information so they can make informed choices based on their own objectives and values.” DEMAND Investor demand / fund reliance — “my clients consistently tell me they also care about how companies conduct their business.” IP Investor protection / decision usefulness — “Material non-financial information is critical in helping investors make informed decisions about their money.” | |||||
| ▸489 | Aug. 3, 2026 | Alan Kohn | No position | Individual | |
Position: No position (unanimous) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework No coded rationale. | |||||
| ▸488 | Aug. 3, 2026 | Ah-li Monahan | Oppose rescission | Individual | Modify / Expand ENV |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: Modify / Expand — asks for stronger or broader disclosure ENV Environmental impact / consequences — “We have serious problems currently with weather extremes, and we know they will only get worse.” | |||||
| ▸487 | Aug. 3, 2026 | A. Mather | 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 need and deserve climate change information” | |||||
| ▸486 | Aug. 3, 2026 | Audrey Fay, Retired World Language Teacher | 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 — “Climate related information should not be suppressed or deleted.” | |||||
| ▸485 | Aug. 3, 2026 | Wanda Webber | Oppose rescission | Individual | CMP ENV FRAG IP |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework CMP Standardization / comparability — “Rescinding these rules would eliminate a national framework intended to make significant climate-related information more consistent, comparable, and accessible.” ENV Environmental impact / consequences — “Communities would lose a critical public source of environmental data.” FRAG Regulatory fragmentation / multi-jurisdictional consistency — “Investors could instead be required to locate information across general SEC filings, voluntary sustainability reports, state disclosure systems, and other company materials.” IP Investor protection / decision usefulness — “Investors could instead be required to locate information across general SEC filings, voluntary sustainability reports, state disclosure systems, and other company materials.” | |||||
| ▸484 | Aug. 3, 2026 | Vicki Presley | Oppose rescission | Individual | Modify / Expand ENV IP |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: Modify / Expand — asks for stronger or broader disclosure ENV Environmental impact / consequences — “This proposal is a critical issue for environmental justice communities.” IP Investor protection / decision usefulness — “Climate disclosures can help investors and the public understand how companies identify significant climate risks, account for severe-weather losses, calculate certain emissions, and describe publicly announced climate targets.” | |||||
| ▸483 | Aug. 3, 2026 | Thomas G Johnson | 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 — “I want my progeny to live in a better climate than will exist only if this rule is kept in place.” | |||||
| ▸482 | Aug. 3, 2026 | Ted King | Oppose rescission | Individual | Modify / Expand ACCT ENV |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: Modify / Expand — asks for stronger or broader disclosure ACCT Stewardship / accountability — “all businesses should be required to present to the public all data related to their environmental impacts.” ENV Environmental impact / consequences — “all businesses should be required to present to the public all data related to their environmental impacts.” | |||||
| ▸481 | Aug. 3, 2026 | Tamara Lewis | Oppose rescission | Individual | Modify / Expand CBA CFR ENV |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: Modify / Expand — asks for stronger or broader disclosure CBA Cost-benefit assessment — “so that we reduce redundancy and get the most efficient results from our data investment” CFR Climate-related financial risk — “to show companies climate risks that will affect them and their communities, to get data (which they can use to budget) in regards to severe-weather effects” ENV Environmental impact / consequences — “to enable all who are affected to state how their actions/proposed action will affect their environment/communities” | |||||
| ▸480 | Aug. 3, 2026 | Sybil E Schlesinger | Oppose rescission | Individual | Modify / Expand ENV IP |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: Modify / Expand — asks for stronger or broader disclosure ENV Environmental impact / consequences — “This proposal is a critical issue for environmental justice communities.” IP Investor protection / decision usefulness — “Climate disclosures can help investors and the public understand how companies identify significant climate risks, account for severe-weather losses, calculate certain emissions, and describe publicly announced climate targets.” | |||||
| ▸479 | Aug. 3, 2026 | Susan Welsford | Oppose rescission | Individual | Modify / Expand CFR CMP ENV FRAG IP GHG12 GOV TARGETS FINSTMT |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: Modify / Expand — asks for stronger or broader disclosure Keep provisions: GHG12 (Scope 1 & 2 emissions), GOV (Governance / risk management), TARGETS (Targets / transition plan), FINSTMT (Financial-statement effects (Reg S-X Art. 14)) CFR Climate-related financial risk — “Certain financial effects connected to severe weather, flooding, drought, wildfires, extreme temperatures, sea-level rise, carbon offsets, and renewable energy credits.” CMP Standardization / comparability — “Rescinding the rules would eliminate a national framework intended to make significant climate-related information more consistent, comparable, and accessible.” ENV Environmental impact / consequences — “Communities would lose a critical public source of environmental data.” FRAG Regulatory fragmentation / multi-jurisdictional consistency — “Investors could instead be required to locate information across general SEC filings, voluntary sustainability reports, state disclosure systems, and other company materials.” IP Investor protection / decision usefulness — “Climate disclosures can help investors and the public understand how companies identify significant climate risks, account for severe-weather losses, calculate certain emissions, and describe publicly announced climate targets.” | |||||
| ▸478 | Aug. 3, 2026 | Sharon Weil | 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 are experiencing the very real consequences of continuing to allow fossil fuels” | |||||
| ▸477 | Aug. 3, 2026 | Robert Posch | 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 — “As an investor, I want to be informed of all risks, including Climate related, prior to making investment decisions.” | |||||
| ▸476 | Aug. 3, 2026 | Robert Killeen | 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 — “account for severe-weather losses” ENV Environmental impact / consequences — “This proposal is a critical issue for environmental justice communities.” IP Investor protection / decision usefulness — “Climate disclosures can help investors and the public understand how companies identify significant climate risks” | |||||
| ▸475 | Aug. 3, 2026 | Richard Lehnert | Oppose rescission | Individual | CFR CMP 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 — “account for severe-weather losses” CMP Standardization / comparability — “make significant climate-related information more consistent, comparable, and accessible” ENV Environmental impact / consequences — “Communities would lose a critical public source of environmental data.” IP Investor protection / decision usefulness — “Climate disclosures can help investors and the public understand how companies identify significant climate risks” | |||||
| ▸474 | Aug. 3, 2026 | Patti Kozlovsky | 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 — “account for severe-weather losses” IP Investor protection / decision usefulness — “help investors and the public understand how these entities identify significant climate risks” | |||||
| ▸473 | Aug. 3, 2026 | Patricia G. Foschi, San Francisco State University | 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 — “Everyday brings a new climate crisis.” | |||||
| ▸472 | Aug. 3, 2026 | Pascal Molineaux | Oppose rescission | Individual | Modify / Expand CFR |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: Modify / Expand — asks for stronger or broader disclosure CFR Climate-related financial risk — “disclose their exposure to and how they take into account these very real climate-related risks” | |||||
| ▸471 | Aug. 3, 2026 | Nina Rollow | 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 — “This would be damaging to our country and our environment.” | |||||
| ▸470 | Aug. 3, 2026 | Melody Andreu | 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 — “Our planet is already under tremendous stress related to global warming and pollution at massive scale.” | |||||
| ▸469 | Aug. 3, 2026 | Meera P | Oppose rescission | Individual | Modify / Expand CFR ENV IP |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: Modify / Expand — asks for stronger or broader disclosure CFR Climate-related financial risk — “account for severe-weather losses” ENV Environmental impact / consequences — “This proposal is a critical issue for environmental justice communities.” IP Investor protection / decision usefulness — “Climate disclosures can help investors and the public understand how companies identify significant climate risks” | |||||
| ▸468 | Aug. 3, 2026 | Mary Beth South | Oppose rescission | Individual | Modify / Expand ENV |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: Modify / Expand — asks for stronger or broader disclosure ENV Environmental impact / consequences — “protecting the environment, the people, and all the flora and fauna of this planet” | |||||
| ▸467 | Aug. 3, 2026 | Martha Robertson | Oppose rescission | Individual | ACCT CFR ENV IP TARGETS FINSTMT |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework Keep provisions: TARGETS (Targets / transition plan), FINSTMT (Financial-statement effects (Reg S-X Art. 14)) ACCT Stewardship / accountability — “how companies identify and plan to manage these risks” CFR Climate-related financial risk — “financial effects that might result from adverse weather events” ENV Environmental impact / consequences — “In an age of rapid global warming and significant risks from climate change” IP Investor protection / decision usefulness — “public and private investors need to know about climate-related risks that have materially affected or are reasonably likely to materially affect the company” | |||||
| ▸466 | Aug. 3, 2026 | Mark Reback | 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 — “account for severe-weather losses” ENV Environmental impact / consequences — “This proposal is a critical issue for environmental justice communities.” IP Investor protection / decision usefulness — “Climate disclosures can help investors and the public understand how companies identify significant climate risks, account for severe-weather losses, calculate certain emissions, and describe publicly announced climate targets.” | |||||
| ▸465 | Aug. 3, 2026 | Mark Neidengard, Senior Staff Design Engineer, Intel Corporation | Oppose rescission | Individual | CAPFORM 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 — “The primary role of government is to lessen friction for public and private transactions in ways that private actors cannot achieve via piecemeal effort.” ENV Environmental impact / consequences — “as well as sound stewardship of our environment and natural resources” IP Investor protection / decision usefulness — “Disclosure rules about climate-related risks are an essential pillar of informed investing and policy-making.” | |||||
| ▸464 | Aug. 3, 2026 | Margaret Schulenberg | Oppose rescission | Individual | ACCT CFR GHG12 GOV TARGETS FINSTMT |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework Keep provisions: GHG12 (Scope 1 & 2 emissions), GOV (Governance / risk management), TARGETS (Targets / transition plan), FINSTMT (Financial-statement effects (Reg S-X Art. 14)) ACCT Stewardship / accountability — “Oversight of climate risks by company leadership;” CFR Climate-related financial risk — “Climate-related risks that have materially affected or are reasonably likely to materially affect the company” | |||||
| ▸463 | Aug. 3, 2026 | Margaret Hepler | 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 — “account for severe-weather losses” ENV Environmental impact / consequences — “This is a critical issue for environmental justice communities.” IP Investor protection / decision usefulness — “Climate disclosures can help investors and the public understand how companies identify significant climate risks, account for severe-weather losses, calculate certain emissions, and describe publicly announced climate targets.” | |||||
| ▸462 | Aug. 3, 2026 | Marcia Fitzgibbons | 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 — “As we have increasing weather -related disturbances, responsible investors need to know the impact of their decisions on the future of our environment on future generations.” IP Investor protection / decision usefulness — “responsible investors need to know the impact of their decisions on the future of our environment on future generations” | |||||
| ▸461 | Aug. 3, 2026 | marc silverman | Oppose rescission | Individual | Modify / Expand CFR ENV IP |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: Modify / Expand — asks for stronger or broader disclosure CFR Climate-related financial risk — “account for severe-weather losses” ENV Environmental impact / consequences — “This proposal is a critical issue for environmental justice.” IP Investor protection / decision usefulness — “Climate disclosures without a doubt help investors and the public understand how companies identify significant climate risks, account for severe-weather losses, calculate certain emissions, and describe publicly announced climate targets.” | |||||
| ▸460 | Aug. 3, 2026 | Louise Priest | Duplicate | Individual | CFR ENV IP |
Position: Duplicate (unanimous) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework CFR Climate-related financial risk — “account for severe-weather losses” ENV Environmental impact / consequences — “This proposal is a critical issue for environmental justice communities.” IP Investor protection / decision usefulness — “Climate disclosures can help investors and the public understand how companies identify significant climate risks, account for severe-weather losses, calculate certain emissions, and describe publicly announced climate targets.” | |||||
| ▸459 | Aug. 3, 2026 | Louise Jean Priest | 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 — “account for severe-weather losses” ENV Environmental impact / consequences — “This proposal is a critical issue for environmental justice communities.” IP Investor protection / decision usefulness — “Climate disclosures can help investors and the public understand how companies identify significant climate risks, account for severe-weather losses, calculate certain emissions, and describe publicly announced climate targets.” | |||||
| ▸458 | Aug. 3, 2026 | Linda Issel | Oppose rescission | Individual | Modify / Expand NR |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: Modify / Expand — asks for stronger or broader disclosure NR No substantive rationale — “Please do NOT rescind climate-related disclosure rules. The rules need to be strengthened, NOT weakened.” | |||||
| ▸457 | Aug. 3, 2026 | Laura Lyons | Oppose rescission | Individual | Modify / Expand CFR CMP ENV FRAG IP |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: Modify / Expand — asks for stronger or broader disclosure CFR Climate-related financial risk — “account for severe-weather losses” CMP Standardization / comparability — “make significant climate-related information more consistent, comparable, and accessible” ENV Environmental impact / consequences — “Communities would lose a critical public source of environmental data.” FRAG Regulatory fragmentation / multi-jurisdictional consistency — “state disclosure systems” IP Investor protection / decision usefulness — “provide investors with information about material climate-related risks in registration statements and annual reports” | |||||
| ▸456 | Aug. 3, 2026 | Lacey Wozny | Oppose rescission | Individual | CFR ENV IP |
Position: Oppose rescission (majority) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework CFR Climate-related financial risk — “account for severe-weather losses” ENV Environmental impact / consequences — “we owe them the decency of our care for people and planet” IP Investor protection / decision usefulness — “Climate disclosures can help investors and the public understand how companies identify significant climate risks, account for severe-weather losses, calculate certain emissions, and describe publicly announced climate targets.” | |||||
| ▸455 | Aug. 3, 2026 | Kristen Minor, Minor Planning & Design | 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 — “Not requiring this information leaves investors and the public-at-large in the dark when it comes to climate risk.” | |||||
| ▸454 | Aug. 3, 2026 | Kathryn Y. | 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 — “Do not eliminate the framework that protects our environment and life as we know it on our planet.” | |||||
| ▸453 | Aug. 3, 2026 | Kathryn Brown | 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 — “account for severe-weather losses” IP Investor protection / decision usefulness — “Climate disclosures can help investors and the public understand how companies identify significant climate risks, account for severe-weather losses, calculate certain emissions, and describe publicly announced climate targets.” | |||||
| ▸452 | Aug. 3, 2026 | Jon M Spangler | Oppose rescission | Individual | ACCT CFR ENV IP |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework ACCT Stewardship / accountability — “Businesses have a moral and ethical obligation to be "good citizens" of their communities and of the planet.” CFR Climate-related financial risk — “businesses whose projects might significantly add to global climate disruption face extensive and costly legal and regulatory approval battles that may end with a project's termination with resulting losses to investors” ENV Environmental impact / consequences — “Environmental factors and human-caused global climate change have a huge impact on the local, state, national, and international economies and on investors.” IP Investor protection / decision usefulness — “Smart investors want all the information we can find to be able to support the businesses and projects that are best for our financial health” | |||||
| ▸451 | Aug. 3, 2026 | Jim Eshelman | No position | Individual | ENV |
Position: No position (unanimous) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework ENV Environmental impact / consequences — “We must preserve our planet.” | |||||
| ▸450 | Aug. 3, 2026 | JC | No position | Individual | ENV |
Position: No position (unanimous) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework ENV Environmental impact / consequences — “effects on our weather” | |||||
| ▸449 | Aug. 3, 2026 | Jason Chan | Oppose rescission | Individual | Modify / Expand ACCT IP |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: Modify / Expand — asks for stronger or broader disclosure ACCT Stewardship / accountability — “Companies won't voluntarily do the right thing unless they are forced to do so.” IP Investor protection / decision usefulness — “provide investors with information about material climate-related risks in registration statements and annual reports” | |||||
| ▸448 | Aug. 3, 2026 | Grace Lappin | 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 — “need clean water, soil and air to live” | |||||
| ▸447 | Aug. 3, 2026 | Fran Teresi | 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 — “Hiding the problem does not make it go away.” ENV Environmental impact / consequences — “Climate change NEEDS to be addressed.” | |||||
| ▸446 | Aug. 3, 2026 | Dr. Steven Bouma-Prediger, Professor of Religion at Hope College in Holland, Michigan | Oppose rescission | Individual | CFR ENV IP |
Position: Oppose rescission (unanimous) · Entity: Individual (majority) Modification posture: No modification requested — no substantive request to change the framework CFR Climate-related financial risk — “account for severe-weather losses” ENV Environmental impact / consequences — “not just for people committed to caring for our home planet” IP Investor protection / decision usefulness — “Climate disclosures not only help investors but also help you and me and our neighbors to understand how companies identify significant climate risks, account for severe-weather losses, calculate certain emissions, and describe publicly announced climate targets.” | |||||
| ▸445 | Aug. 3, 2026 | Don Dicken | No position | Individual | CFR IP |
Position: No position (unanimous) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework CFR Climate-related financial risk — “owning a stock that requires huge investments to catch up could be very expensive.” IP Investor protection / decision usefulness — “how a company treats our climate is an important consideration.” | |||||
| ▸444 | Aug. 3, 2026 | Denise Ryan | Oppose rescission | Individual | Modify / Expand ENV |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: Modify / Expand — asks for stronger or broader disclosure ENV Environmental impact / consequences — “the hazards of climate change” | |||||
| ▸443 | Aug. 3, 2026 | Chris Osborne | Oppose rescission | Individual | Fallback / Compromise ACCT CFR GHG12 GOV TARGETS FINSTMT |
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 Keep provisions: GHG12 (Scope 1 & 2 emissions), GOV (Governance / risk management), TARGETS (Targets / transition plan), FINSTMT (Financial-statement effects (Reg S-X Art. 14)) ACCT Stewardship / accountability — “Oversight of climate risks by company leadership;” CFR Climate-related financial risk — “Certain financial effects connected to severe weather, flooding, drought, wildfires, extreme temperatures, sea-level rise, carbon offsets, and renewable energy credits.” | |||||
| ▸442 | Aug. 3, 2026 | Barb Wood | 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 very real and we need all hands to help fight this environmental disaster” | |||||
| ▸441 | Aug. 3, 2026 | As Eriers | 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 — “account for severe-weather losses” ENV Environmental impact / consequences — “This proposal is a critical issue for environmental justice communities.” IP Investor protection / decision usefulness — “Climate disclosures can help investors and the public understand how companies identify significant climate risks, account for severe-weather losses, calculate certain emissions, and describe publicly announced climate targets.” | |||||
| ▸440 | Aug. 3, 2026 | Anonymous | 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 — “Please do not rescind climate disclosure rules.” | |||||
| ▸439 | Aug. 3, 2026 | Anonymous | 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 — “Do not roll back Climate Change Rules.” | |||||
| ▸438 | Aug. 3, 2026 | Amanda Hammerstone | 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 — “account for severe-weather losses” ENV Environmental impact / consequences — “This proposal is a critical issue for environmental justice communities.” IP Investor protection / decision usefulness — “Climate disclosures can help investors and the public understand how companies identify significant climate risks, account for severe-weather losses, calculate certain emissions, and describe publicly announced climate targets.” | |||||
| ▸435 | Aug. 3, 2026 | AFT, American Federation of Labor and Congress of Industrial Organizations (AFL-CIO), Americans for Financial Reform Education Fund, Chevedden Corporate Governance, Harrington Investments, Inc., Investor Advocates for Social Justice, Muslims for Just Futures, National Education Association (NEA), NorthStar Asset Management, People Power United, Public Citizen, Service Employees International Union (SEIU), SOC Investment Group, United Church Funds, and Zevin Asset Management | Oppose rescission | Investor / asset manager (institutional) | AUTH CAPFORM CMP DEMAND INSUFF IP PP |
Position: Oppose rescission (unanimous) · Entity: Investor / asset manager (institutional) (unanimous) Modification posture: No modification requested — no substantive request to change the framework AUTH Statutory authority / major-questions (either direction) — “Section 7(a)(1) of the Securities Act and sections 12 and 13 of the Securities Exchange Act grant the SEC authority to require “such other information” as it determines is “necessary or appropriate in the public interest or for the protection of investors”” CAPFORM Market efficiency / capital formation — “reduced disclosure would undermine capital formation, as reduced transparency may result in investors seeking a higher risk premium” CMP Standardization / comparability — “the reliability and comparability of the information would also be impaired due to the lack of specific SEC requirements and uniformity of disclosures” DEMAND Investor demand / fund reliance — “270 investors mentioned requiring climate-risk disclosures in the 10-K and 97 percent of those who did supported it, and 296 investors mentioned aligning disclosures with the recommendations of the Task Force on Climate-related Financial Disclosures (TCFD) and 100 percent of those who did supported it” INSUFF Insufficient / incoherent legal basis (either direction) — “The aboutface of the staff’s perspective a mere two years later is notable and brings into doubt the legal consistency and rule of law that underpin our capital markets and raises significant doubt as to the integrity of this process” IP Investor protection / decision usefulness — “the SEC is attempting to turn the concept of materiality on its head such that issuers can have free rein to trump reasonable investors’ determination of what is material” PP Political pressure / regulatory capture — “the SEC has made these broad pronouncements about its authority at a time when the agency lacks the political balance mandated by the Securities Exchange Act of 1934 and has not met the statutory requirement that appointments to the SEC alternate by party” | |||||
| ▸434 | Aug. 3, 2026 | Deborah B. Goldberg, Massachusetts State Treasurer & Receiver General | Oppose rescission | Government / elected official | Modify / Improve or Clarify CFR CMP DEMAND IP |
Position: Oppose rescission (unanimous) · Entity: Government / elected official (majority) Modification posture: Modify / Improve or Clarify — asks for a revised, clarified or better-designed framework CFR Climate-related financial risk — “Climate change presents physical, transition, regulatory, and market-driven risks that affect the financial performance of the companies in which we invest.” CMP Standardization / comparability — “Standardized, comparable disclosure at scale is what allows me, as a Trustee, to exercise informed and prudent oversight on behalf of our beneficiaries” DEMAND Investor demand / fund reliance — “Climate disclosure rules would allow for such disclosures at the scale that universal owners need.” IP Investor protection / decision usefulness — “Standardized, comparable disclosure at scale is what allows me, as a Trustee, to exercise informed and prudent oversight on behalf of our beneficiaries” | |||||
| ▸433 | Aug. 3, 2026 | Don Andrews, Executive Director, Pension Investment Association of Canada | Oppose rescission | Investor / asset manager (institutional) | Modify / Improve or Clarify CAPFORM CB CFR CMP DEMAND FRAG IP |
Position: Oppose rescission (majority) · Entity: Investor / asset manager (institutional) (unanimous) Modification posture: Modify / Improve or Clarify — asks for a revised, clarified or better-designed framework CAPFORM Market efficiency / capital formation — “Such an approach would help ensure that U.S. capital markets remain both efficient and integrated within the broader global financial system.” CB Compliance burden — “alignment with IFRS S2 can help reduce reporting burdens by limiting the need for issuers, particularly multinational companies, to navigate multiple, potentially inconsistent regulatory regimes.” CFR Climate-related financial risk — “Climate-related risks, where financially material, are already integrated into investment analysis across asset classes.” CMP Standardization / comparability — “Alignment with these frameworks supports interoperability, reduces fragmentation, and enhances comparability for investors assessing companies across global markets.” DEMAND Investor demand / fund reliance — “Our investor members depend on transparent, comparable, and reliable information to evaluate risks and opportunities that may affect long-term value creation.” FRAG Regulatory fragmentation / multi-jurisdictional consistency — “divergence in disclosure requirements may increase complexity, reduce comparability, and contribute to market fragmentation.” IP Investor protection / decision usefulness — “Our investor members depend on transparent, comparable, and reliable information to evaluate risks and opportunities that may affect long-term value creation.” | |||||
| ▸432 | Aug. 3, 2026 | James R. Copland, Senior Fellow and Director of Legal Policy, Manhattan Institute for Policy Research | Support rescission | Business trade association / advocacy org | 1A AUTH CAPFORM CB CBA CFR FRAG INSUFF IP REDUN |
Position: Support rescission (unanimous) · Entity: Business trade association / advocacy org (majority) Modification posture: No modification requested — no substantive request to change the framework 1A Compelled speech / First Amendment (either direction) — “failed adequately to assess costs and capital-formation effects, and raised constitutional concerns.” AUTH Statutory authority / major-questions (either direction) — “the SEC has broad but bounded disclosure authority. It does not possess a general license to compel public companies to produce information on any politically salient subject that interests a subset of investors.” CAPFORM Market efficiency / capital formation — “whether the proposed rule or regulation "will promote efficiency, competition, and capital formation."” CB Compliance burden — “Companies would need lawyers, accountants, engineers, consultants, data vendors, assurance providers, information systems, internal controls, and board and management time.” CBA Cost-benefit assessment — “The rescission proposal updates and aggregates those estimates and projects roughly $4.9 billion in annualized savings.” CFR Climate-related financial risk — “An insurer with concentrated catastrophe exposure, an energy producer facing material transition costs, a manufacturer dependent on water-stressed facilities, or a coastal property owner may need extensive climate disclosure.” FRAG Regulatory fragmentation / multi-jurisdictional consistency — “California enacted two statutes, SB 253 (the "Climate Corporate Data Accountability Act") and SB 261 (the "Climate-Related Financial Risk Act"), which purported to regulate climate disclosures for all companies above a certain size doing business in California.” INSUFF Insufficient / incoherent legal basis (either direction) — “Reliance interests do not counsel otherwise. The rules were stayed before effectiveness, and no issuer developed a settled legal entitlement to their operation.” IP Investor protection / decision usefulness — “Materiality is not an obstacle to investor protection; it is a protection against information overload and the use of securities filings to pursue objectives remote from reasonable investors' economic interests.” REDUN Redundant — existing rules, materiality regime, or voluntary reporting already suffice — “Existing law already applies that standard to climate matters. Regulation S-K Items 101, 103, 105, and 303 require disclosure, as applicable, concerning the business, material legal proceedings, material risk factors, and known trends or uncertainties reasonably likely to affect results or financial condition.” | |||||
| ▸431 | Aug. 3, 2026 | Attorneys General of Massachusetts, D.C., California, New York, Arizona, Connecticut, Delaware, Hawaii, Illinois, Maine, Maryland, Minnesota, New Jersey, New Mexico, Nevada, Oregon, Rhode Island, Vermont, Virginia, Washington, and Wisconsin | Oppose rescission | Government / elected official | ACCT AUTH CAPFORM CFR CMP DEMAND INSUFF IP WHIP |
Position: Oppose rescission (unanimous) · Entity: Government / elected official (unanimous) Modification posture: No modification requested — no substantive request to change the framework ACCT Stewardship / accountability — “Access to standardized and reliable information related to climate-related risk also” AUTH Statutory authority / major-questions (either direction) — “When Congress enacted the Securities Act of 1933 and the Securities Exchange Act” CAPFORM Market efficiency / capital formation — “Congress has directed the Commission, when engaged” CFR Climate-related financial risk — “significantly affect companies' financial performance and long-term value.” CMP Standardization / comparability — “consistency, comparability, and reliability” DEMAND Investor demand / fund reliance — “In response to the resounding support from investors and registrants alike for” INSUFF Insufficient / incoherent legal basis (either direction) — “The Proposed Rescission fails to provide a reasoned basis for abandoning the” IP Investor protection / decision usefulness — “Standardized and reliable information regarding climate-related risks allows investors to” WHIP Regulatory whiplash / reliance interests / costs already incurred — “many of our States will need to expend significant time and resources to independently obtain” | |||||
| ▸430 | Aug. 3, 2026 | Cambria Allen-Ratzlaff, CEO, Principles for Responsible Investment | Oppose rescission | Investor / asset manager (institutional) | Fallback / Compromise ACCT AUTH CAPFORM CBA 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 ACCT Stewardship / accountability — “uniform climate
disclosures would reduce greenwashing” AUTH Statutory authority / major-questions (either direction) — “The SEC had legal authority to promulgate climate disclosure rules.” CAPFORM Market efficiency / capital formation — “Efficient markets and capital formation depend on robust, high-quality information
environments.” CBA Cost-benefit assessment — “The Proposal's cost-benefit analysis is inadequate to support rescission of the Final
Rules.” CFR Climate-related financial risk — “climate-related risks can
demonstrably affect issuers' financial performance, resilience and valuation” CMP Standardization / comparability — “PRI signatories rely on consistent and comparable disclosure of material information,
including information about climate-related risks and opportunities.” DEMAND Investor demand / fund reliance — “They address a clear demand from investors for consistent and comparable climate-related
information.” FRAG Regulatory fragmentation / multi-jurisdictional consistency — “further ceding the ground of regulating
disclosure to foreign law makers and US states” INSUFF Insufficient / incoherent legal basis (either direction) — “The SEC did not meet its obligations under the Administrative Procedure Act in
proposing to rescind the Final Rules.” IP Investor protection / decision usefulness — “Investors use climate-related information in their investment, stewardship and
reporting processes as part of their fiduciary duty to clients and beneficiaries.” WHIP Regulatory whiplash / reliance interests / costs already incurred — “at least one asset owner investor has indicated their reliance on
the Final Rules and that the Proposal would meaningfully interfere with their statutory
responsibilities to analyze climate-related financial risks” | |||||
| ▸429 | Aug. 3, 2026 | Alexa White, Ph.D. Policy Director, Hip Hop Caucus | Oppose rescission | Environmental / ESG advocacy org | ACCT CFR CMP ENV IP |
Position: Oppose rescission (unanimous) · Entity: Environmental / ESG advocacy org (unanimous) Modification posture: No modification requested — no substantive request to change the framework ACCT Stewardship / accountability — “advocate for strong environmental policies, and work to hold polluters accountable.” CFR Climate-related financial risk — “Material climate risks can disrupt facilities and supply chains, raise insurance and operating costs, affect workforce stability, impair assets, and constrain access to capital.” CMP Standardization / comparability — “raised investors' research costs and hindered company-to-company comparison.” ENV Environmental impact / consequences — “EPA has found that socially vulnerable populations face disproportionate projected risks from extreme heat, flooding, air pollution, and climate-related labor losses.” IP Investor protection / decision usefulness — “Investors need consistent information explaining how companies identify and manage financially material risks arising from the location and operation of their assets.” | |||||
| ▸428 | Aug. 3, 2026 | Alexander Schay, Managing Director, W.K. Associates, Inc., and Paul Bugala, Principal, Othello Consulting LLC | Oppose rescission | Investor / asset manager (institutional) | CAPFORM CFR DEMAND IP |
Position: Oppose rescission (unanimous) · Entity: Investor / asset manager (institutional) (majority) Modification posture: No modification requested — no substantive request to change the framework CAPFORM Market efficiency / capital formation — “maintain efficient markets and facilitate capital formation” CFR Climate-related financial risk — “investors can better understand the risks of oil and gas demand uncertainty to the securities of exploration and production companies” DEMAND Investor demand / fund reliance — “Our study is one of the many references to the use of emissions data in investment decision-making submitted during the comment period” IP Investor protection / decision usefulness — “would deprive market participants of disclosures that would help protect investors, maintain efficient markets and facilitate capital formation” | |||||
| ▸427 | Aug. 3, 2026 | Will Hild, Executive Director, Consumers' Research | Support rescission | Business trade association / advocacy org | AUTH CAPFORM CBA DEMAND IMMAT IP PP REDUN WHIP |
Position: Support rescission (unanimous) · Entity: Business trade association / advocacy org (unanimous) Modification posture: No modification requested — no substantive request to change the framework AUTH Statutory authority / major-questions (either direction) — “Consumers' Research also agrees with the Commission's conclusion that the Final Rules exceed the statutory limits on the agency's disclosure authority” CAPFORM Market efficiency / capital formation — “The burdens can deter companies from becoming or remaining public, reduce investment and innovation, and ultimately narrow the investment opportunities available to retail investors.” CBA Cost-benefit assessment — “The proposed rescission appropriately asks whether the informational benefits of a disclosure mandate, viewed from the perspective of the reasonable investor, justify the costs of producing it.” DEMAND Investor demand / fund reliance — “these organizations were created to advance climate-related disclosure or policy goals, and their institutional signatories substantially overlapped” IMMAT Immaterial / not decision-useful — “ESG profile ranked last on average among the six investment factors presented” IP Investor protection / decision usefulness — “The proposed rescission correctly returns the Commission's disclosure framework to information that a reasonable investor would consider important in buying or selling securities” PP Political pressure / regulatory capture — “Public pension funds are administered by stewards appointed by elected officials who may have political objectives.” REDUN Redundant — existing rules, materiality regime, or voluntary reporting already suffice — “Existing, materiality-based disclosures and market forces can provide climate information when investors need it.” WHIP Regulatory whiplash / reliance interests / costs already incurred — “The Final Rules were stayed before becoming effective. The proposed rescission therefore does not upset a settled disclosure system on which retail investors reasonably relied.” | |||||
| ▸426 | Aug. 3, 2026 | Josh Zinner, CEO, Interfaith Center on Corporate Responsibility, Erica Lasdon, Director, Climate Change and Environmental Justice and Tracey Rembert, Associate Director, Climate Change and Environmental Justice | Oppose rescission | Environmental / ESG advocacy org | 1A ACCT AUTH CAPFORM CB CBA CFR CMP DEMAND ENV FRAG INSUFF IP PP |
Position: Oppose rescission (unanimous) · Entity: Environmental / ESG advocacy org (majority) Modification posture: No modification requested — no substantive request to change the framework 1A Compelled speech / First Amendment (either direction) — “some commenters challenged the thenproposed rules as compelled speech in violation of the First Amendment” ACCT Stewardship / accountability — “the build-out results in comparability, reliability, and” AUTH Statutory authority / major-questions (either direction) — “The SEC Has Clear Statutory Authority to Promulgate, Monitor, and Enforce” CAPFORM Market efficiency / capital formation — “promote efficiency, competition, and capital formation.”” CB Compliance burden — “burdensome for companies to be required to respond to multitudes of requests received in” CBA Cost-benefit assessment — “The SEC’s cost-benefit analysis was not robust, in part because it did not seek the views” CFR Climate-related financial risk — “A 2025 industry report found about 75% of investors globally are assessing climaterelated financial risks and opportunities within their investment portfolios.” CMP Standardization / comparability — “importance to investors of robust, standardized, and comparable corporate climate risk” DEMAND Investor demand / fund reliance — “investors have increased their demand for more detailed information about the” ENV Environmental impact / consequences — “companies on the environmental impacts of their operations” FRAG Regulatory fragmentation / multi-jurisdictional consistency — “Disclosure requirements are also mandated in the European Union through the Corporate” INSUFF Insufficient / incoherent legal basis (either direction) — “codifying the disclosure of information on which investors have long relied. Its proposal to” IP Investor protection / decision usefulness — “information is important for investors striving to make prudent decisions as fiduciaries.” PP Political pressure / regulatory capture — “The SEC, in reaching a policy decision to rescind its own Rules based on a same-branch” | |||||
| ▸425 | Aug. 3, 2026 | Jacob Arlein, CEO, Stok, Inc. | Oppose rescission | Issuer / Corporate — current | CFR CMP DEMAND FRAG IP |
Position: Oppose rescission (unanimous) · Entity: Issuer / Corporate — current (unanimous) Modification posture: No modification requested — no substantive request to change the framework CFR Climate-related financial risk — “concealing major vulnerabilities in the global financial system” CMP Standardization / comparability — “two companies with materially identical operations can report substantially different greenhouse gas emissions” DEMAND Investor demand / fund reliance — “investors demand that our clients produce information on their environmental and climate impacts, opportunities, and risks” FRAG Regulatory fragmentation / multi-jurisdictional consistency — “Our clients will continue to report under California's SB 253 and SB 261, the EU's Corporate Sustainability Reporting Directive” IP Investor protection / decision usefulness — “corporate disclosures often do not adequately capture important and systemic financial impacts that issuers face, concealing major vulnerabilities in the global financial system and preventing effective risk management and efficient capital allocation” | |||||
| ▸424 | Aug. 3, 2026 | Tyler Kubik, Counsel, American Fuel & Petrochemical Manufacturers (AFPM) | Support rescission | Business trade association / advocacy org | 1A AUTH CAPFORM CB CBA CMP DEMAND FRAG IMMAT INSUFF IP REDUN WHIP |
Position: Support rescission (unanimous) · Entity: Business trade association / advocacy org (unanimous) Modification posture: No modification requested — no substantive request to change the framework 1A Compelled speech / First Amendment (either direction) — “The Disclosure Rule impermissibly compels speech under the First Amendment.” AUTH Statutory authority / major-questions (either direction) — “the SEC effectively asserted an unbridled authority to compel information disclosure” CAPFORM Market efficiency / capital formation — “A continued decline in public listings harms the broader economy by reducing liquidity, limiting investment opportunities for retail investors” CB Compliance burden — “Attestation standards for emissions data remain unsettled and inconsistently applied” CBA Cost-benefit assessment — “It Is Unnecessary, Unreasonable, Unduly Burdensome, and Provides No Material Benefit to Investors” CMP Standardization / comparability — “Different companies will reasonably adopt different time horizons, modeling approaches, and organizational boundaries, rendering cross-firm comparisons unreliable.” DEMAND Investor demand / fund reliance — “certain specialized investors and funds have expressed strong interest in granular climate data” FRAG Regulatory fragmentation / multi-jurisdictional consistency — “Laws like California's SB 261 requires covered companies doing business in California to publish a separate, standalone biennial climate-related financial risk report” IMMAT Immaterial / not decision-useful — “non-material, speculative, forward-looking, and third-party-dependent information on climate science” INSUFF Insufficient / incoherent legal basis (either direction) — “the requirement is both constitutionally suspect (as compelled speech on speculative matters) and arbitrary and capricious under the Administrative Procedure Act” IP Investor protection / decision usefulness — ““investor demand” cannot be equated with the needs of a reasonable investor whom the securities laws are designed to protect” REDUN Redundant — existing rules, materiality regime, or voluntary reporting already suffice — “Existing rules under Regulation S-K, combined with voluntary sustainability reporting, already provide investors with material climate-related information.” WHIP Regulatory whiplash / reliance interests / costs already incurred — “There are no significant reliance interests that weigh against rescission.” | |||||
| ▸423 | Aug. 3, 2026 | State of West Virginia, Office of the Attorney General and 24 Other States | Support rescission | Government / elected official | 1A AUTH CAPFORM CB CBA IMMAT INSUFF IP REDUN |
Position: Support rescission (unanimous) · Entity: Government / elected official (unanimous) Modification posture: No modification requested — no substantive request to change the framework 1A Compelled speech / First Amendment (either direction) — “First Amendment questions the States raised in their 2022 comments” AUTH Statutory authority / major-questions (either direction) — “I. The Commission Correctly Concludes That It Lacked Statutory Authority To Adopt” CAPFORM Market efficiency / capital formation — “the Commission's policy objectives of facilitating capital formation and promoting public” CB Compliance burden — “The Final Rules would have imposed extraordinary costs.” CBA Cost-benefit assessment — “C. The Final Rules' Costs Were Never Justified By Their Purported Benefits.” IMMAT Immaterial / not decision-useful — “matter of law—even when financially immaterial” INSUFF Insufficient / incoherent legal basis (either direction) — “would flunk arbitrary-and-capricious review” IP Investor protection / decision usefulness — “protects investors from being buried in an avalanche of trivial information” REDUN Redundant — existing rules, materiality regime, or voluntary reporting already suffice — “A. Existing Disclosure Requirements Already Elicit Material Climate Information.” | |||||
| ▸422 | Aug. 3, 2026 | Kole Kelley, Director & Senior Attorney, Grady J. Block, Associate Attorney, Center For American Prosperity & Energy, Mountain States Legal Foundation | Support rescission | Legal practitioner | 1A AUTH CAPFORM CB CBA CMP FRAG IMMAT INSUFF IP 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) — “raised serious First Amendment concerns” AUTH Statutory authority / major-questions (either direction) — “An administrative agency has no inherent regulatory authority. It may exercise only the powers Congress granted” CAPFORM Market efficiency / capital formation — “impede the Commission's statutory objective of facilitating capital formation” CB Compliance burden — “The Commission estimated that average annual compliance costs could exceed $739,000 for certain registrants.” CBA Cost-benefit assessment — “its costs and limited incremental benefits independently support rescission” CMP Standardization / comparability — “Nor did the Rules guarantee meaningful comparability. Emissions calculations and other climate disclosures depend on judgments about boundaries, methodologies, assumptions, factors, estimates, and materiality.” FRAG Regulatory fragmentation / multi-jurisdictional consistency — “A patchwork of state climate mandates would increase the cost of becoming or remaining a public company” IMMAT Immaterial / not decision-useful — “The Rules Abandoned Registrant-Specific Materiality in Favor of an Overly Prescriptive Disclosure Code” INSUFF Insufficient / incoherent legal basis (either direction) — “Courts have invalidated Commission rules that failed to adequately assess economic consequences or substantiate their regulatory choices.” IP Investor protection / decision usefulness — “information useful to a particular investment strategy or policy objective does not automatically become an appropriate subject of mandatory federal reporting” REDUN Redundant — existing rules, materiality regime, or voluntary reporting already suffice — “Longstanding Commission rules, accounting requirements, and antifraud provisions reach such information when it is material” | |||||
| ▸421 | Aug. 3, 2026 | Concerned Citizen | Oppose rescission | Individual | AUTH CFR CMP INSUFF IP |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework AUTH Statutory authority / major-questions (either direction) — “has never been limited to a fixed inventory of disclosure topics existing in 1933 or 1934” CFR Climate-related financial risk — “Credit rating agencies now incorporate climate risk directly into the credit analysis that determines the cost of capital for issuers” CMP Standardization / comparability — “had produced inconsistent, incomplete, and non-comparable climate disclosure across registrants, which was the evidentiary basis for adopting a more structured framework in the first place” INSUFF Insufficient / incoherent legal basis (either direction) — “the proposed rescission fails the reasoned-decisionmaking standard of 5 U.S.C. 553(c) and State Farm” IP Investor protection / decision usefulness — “the standard the Supreme Court articulated in TSC Industries, Inc. v. Northway, Inc., 426 U.S. 438 (1976), holding that an omitted fact is material if there is a substantial likelihood that a reasonable investor would have viewed it as significantly altering the total mix of information made available” | |||||
| ▸420 | Aug. 3, 2026 | Neil A. Hansen, Senior Vice President and Chief Financial Officer, ExxonMobil | Support rescission | Issuer / Corporate — current | Fallback / Compromise AUTH CAPFORM CB CBA CFR CMP ENV FRAG IMMAT IP REDUN WHIP |
Position: Support rescission (unanimous) · Entity: Issuer / Corporate — current (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) — “The return to this approach is consistent with the SEC's mission to protect investors, its statutory authority under the federal securities laws, and decades of judicial precedent” CAPFORM Market efficiency / capital formation — “This effect conflicts with the Commission's statutory purpose to facilitate the formation of capital.” CB Compliance burden — “we have incurred more than $100 million in costs to assess, develop, implement, and maintain compliance-related processes and controls” CBA Cost-benefit assessment — “The 2024 Rules would therefore impose considerable and ongoing operational costs on the Company and its shareholders without providing a commensurate or material incremental benefit to investors or the environment.” CFR Climate-related financial risk — “discusses climate change, the physical risks it poses, and the energy transition as risk factors under Item 105 (Risk Factors)” CMP Standardization / comparability — “the complexities of this proposed disclosure and the individual judgment required will prevent the consistency and comparability across companies the Commission seeks.” ENV Environmental impact / consequences — “could increase overall societal emissions if energy production remains with higher emission supply” FRAG Regulatory fragmentation / multi-jurisdictional consistency — “complex climate-disclosure infrastructure layered on top of existing disclosure controls and procedures, financial-reporting controls, voluntary sustainability-reporting systems, and other evolving international regulatory regimes.” IMMAT Immaterial / not decision-useful — “The Proposal's lengthy list of prescriptive requirements is also likely to overwhelm investors with granular, speculative, and immaterial information.” IP Investor protection / decision usefulness — “provide investors with decision-useful information that is financially material” REDUN Redundant — existing rules, materiality regime, or voluntary reporting already suffice — “The 2024 Rules are unnecessary as federal securities regulation already requires disclosure of material climate-related information.” WHIP Regulatory whiplash / reliance interests / costs already incurred — “because the 2024 Rules were stayed pending judicial review and never became operative, rescission would not disrupt settled reliance interests or require transition periods.” | |||||
| ▸419 | Aug. 3, 2026 | David Hurley | Oppose rescission | Individual | Modify / Expand NR |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: Modify / Expand — asks for stronger or broader disclosure NR No substantive rationale | |||||
| ▸418 | Aug. 3, 2026 | Cathy Brinkley | 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 — “Do not get rid of oversight of climate issues.” | |||||
| ▸417 | Aug. 3, 2026 | Laura Brody | Oppose rescission | Individual | Modify / Expand CFR CMP ENV IP |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: Modify / Expand — asks for stronger or broader disclosure CFR Climate-related financial risk — “account for severe-weather losses, calculate certain emissions” CMP Standardization / comparability — “Rescinding the rules would eliminate a national framework intended to make significant climate-related information more consistent, comparable, and accessible.” ENV Environmental impact / consequences — “As a nation, we are quite literally on fire and in grave danger.” IP Investor protection / decision usefulness — “Climate disclosures help investors and the public understand how companies identify significant climate risks” | |||||
| ▸416 | Aug. 3, 2026 | Karen Jones | Oppose rescission | Individual | CMP ENV IP |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework CMP Standardization / comparability — “Rescinding the rules would eliminate a national framework intended to make significant climate-related information more consistent, comparable, and accessible.” ENV Environmental impact / consequences — “Communities would lose a critical public source of environmental data.” IP Investor protection / decision usefulness — “The rules requiring publicly traded companies to provide investors with information about material climate-related risks in registration statements and annual reports is of utmost important for our health.” | |||||
| ▸415 | Aug. 3, 2026 | Susan | Oppose rescission | Individual | Modify / Expand ENV |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: Modify / Expand — asks for stronger or broader disclosure ENV Environmental impact / consequences — “Anyone can see that climate change is happening and we need to do all we can to alleviate the suffering that is being caused.” | |||||
| ▸414 | Aug. 3, 2026 | Tyrone Lee | No position | Individual | |
Position: No position (unanimous) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework No coded rationale. | |||||
| ▸413 | Aug. 3, 2026 | Nathaniel Lundin, Teaching Professor, University of Oregon | 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 — “account for severe-weather losses, calculate certain emissions” ENV Environmental impact / consequences — “This proposal is a critical issue for environmental justice communities.” IP Investor protection / decision usefulness — “Climate disclosures can help investors and the public understand how companies identify significant climate risks” | |||||
| ▸412 | Aug. 3, 2026 | James U. Mundy III, Retired Education Administrator | 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 | |||||
| ▸411 | Aug. 3, 2026 | Mark Messing | 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 — “account for severe-weather losses, calculate certain emissions” IP Investor protection / decision usefulness — “Climate disclosures can help investors and the public understand how companies identify significant climate risks” | |||||
| ▸410 | Aug. 3, 2026 | Gary Stackpole sr | 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 — “To rely on companies or other individuals to inquire any climate conditions, whether they should be meet or not, any climate issues would solely be up to their responsibility! And that is very risky!” | |||||
| ▸409 | Aug. 3, 2026 | R Gary Walker | Oppose rescission | Individual | ACCT CFR ENV FINSTMT |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework Keep provisions: FINSTMT (Financial-statement effects (Reg S-X Art. 14)) ACCT Stewardship / accountability — “Denial and fraud must be avoided.” CFR Climate-related financial risk — “Corporations must include the effects of Climate Change in their profit/loss projections, honestly.” ENV Environmental impact / consequences — “Climate Change is real, and so is the devastation that is already spreading around the world.” | |||||
| ▸408 | Aug. 3, 2026 | Gina Truex | Oppose rescission | Individual | ENV PP |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework ENV Environmental impact / consequences — “STOP KILLING OUR EARTH NOW!” PP Political pressure / regulatory capture — “The current administration is botching climate and weather
Statistics to support its crazy fantasy that our children and future populations are dispensable ….as long as they personally make billions of $$$ off of decreasing standards to line their pockets.” | |||||
| ▸407 | Aug. 3, 2026 | Katharine Tussing | 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 — “Please do not rescind your 2024 climate-related disclosure rules.” | |||||
| ▸406 | Aug. 3, 2026 | Sheila Gloekler | 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 — “Nothing else matters if our planet dies. They must be stopped before they kill us all!” | |||||
| ▸405 | Aug. 3, 2026 | Margaret Katranides | 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 — “expose the behind-the-scenes actions of businesses that are worsening the warming of the planet” ENV Environmental impact / consequences — “The two biggest threats to US society are climate change, and big money in our elections.” | |||||
| ▸404 | Aug. 3, 2026 | Vivian Dowell | 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 need these protections for our environment!” | |||||
| ▸403 | Aug. 3, 2026 | Liselle McFletcher | Oppose rescission | Individual | Modify / Expand CFR ENV IP |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: Modify / Expand — asks for stronger or broader disclosure CFR Climate-related financial risk — “account for severe-weather losses” ENV Environmental impact / consequences — “This proposal is a critical issue for environmental justice communities. Public companies own and operate fossil fuel, petrochemical, utility, transportation, manufacturing, housing, insurance, and financial assets in communities across the country.” IP Investor protection / decision usefulness — “Climate disclosures can help investors and the public understand how companies identify significant climate risks, account for severe-weather losses, calculate certain emissions, and describe publicly announced climate targets.” | |||||
| ▸402 | Aug. 3, 2026 | Anne Blanford, JD | 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 — “I want to know how vulnerable companies are to climate change.” IP Investor protection / decision usefulness — “I want to know how vulnerable companies are to climate change.” | |||||
| ▸401 | Aug. 3, 2026 | Elaine Hering | Oppose rescission | Individual | Modify / Expand ACCT ENV |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: Modify / Expand — asks for stronger or broader disclosure ACCT Stewardship / accountability — “The SEC is not improving anything, rather it is destroying all of human habitat by not addressing the climate crisis with urgency” ENV Environmental impact / consequences — “this very real and devastating crisis destroying all lives” | |||||
| ▸400 | Aug. 3, 2026 | Nora Privitera, Chair, Federal Team 350 Bay Area Action | Oppose rescission | Environmental / ESG advocacy org | ACCT ENV |
Position: Oppose rescission (unanimous) · Entity: Environmental / ESG advocacy org (unanimous) Modification posture: No modification requested — no substantive request to change the framework ACCT Stewardship / accountability — “This is government's job; to protect the public. Do your job.” ENV Environmental impact / consequences — “This summer Europe has seen the highest temperatures in its history, while France, Spain and Greece are battling massive wildfires that threaten hundreds of thousands of people.” | |||||
| ▸399 | Aug. 3, 2026 | Elizabeth Thelen | No position | Individual | CFR ENV |
Position: No position (majority) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework CFR Climate-related financial risk — “It is affecting the full faith and credit of the US dollar.” ENV Environmental impact / consequences — “Burning fossil fuel is causing massive damage to the earth.” | |||||
| ▸398 | Aug. 3, 2026 | Michael Spencer | 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 — “everybody is held responsible for their climate impact” ENV Environmental impact / consequences — “we are in a catastrophic climate crisis” | |||||
| ▸397 | Aug. 3, 2026 | limpal | 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 — “Roll forward not back” | |||||
| ▸396 | Aug. 3, 2026 | Mike Andrewjeski | Oppose rescission | Individual | Modify / Expand CFR ENV IP |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: Modify / Expand — asks for stronger or broader disclosure CFR Climate-related financial risk — “account for severe-weather losses” ENV Environmental impact / consequences — “This proposal is a critical issue for environmental justice communities.” IP Investor protection / decision usefulness — “Climate disclosures can help investors and the public understand how companies identify significant climate risks, account for severe-weather losses, calculate certain emissions, and describe publicly announced climate targets.” | |||||
| ▸395 | Aug. 3, 2026 | Anonymous | 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 — “account for severe-weather losses” IP Investor protection / decision usefulness — “Climate disclosures can help investors and the public understand how companies identify significant climate risks, account for severe-weather losses, calculate certain emissions, and describe publicly announced climate targets.” | |||||
| ▸394 | Aug. 3, 2026 | Robert Trujillo | 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 — “account for severe-weather losses” IP Investor protection / decision usefulness — “Climate disclosures can help investors and the public understand how companies identify significant climate risks, account for severe-weather losses, calculate certain emissions, and describe publicly announced climate targets.” | |||||
| ▸393 | Aug. 3, 2026 | Phoenix Muchowski | 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 — “These disclosure rules allow consumers and investors to make fully educated choices and there is no reason to take away that information.” | |||||
| ▸392 | Aug. 3, 2026 | Nan Brunskill | Oppose rescission | Individual | Modify / Expand AUTH CAPFORM CFR CMP IP |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: Modify / Expand — asks for stronger or broader disclosure AUTH Statutory authority / major-questions (either direction) — “The SEC's mission includes protecting investors and maintaining fair, orderly, and efficient markets. Material climate-related risks clearly fall within that mission” CAPFORM Market efficiency / capital formation — “promotes fair, efficient, and transparent markets” CFR Climate-related financial risk — “Climate-related events such as flooding, extreme heat, drought, wildfires, and severe storms already create significant financial risks across many sectors of the economy.” CMP Standardization / comparability — “reducing transparency and comparability” IP Investor protection / decision usefulness — “Investors deserve access to consistent, comparable, and reliable information about material climate-related risks that could affect a company's financial performance and long-term stability.” | |||||
| ▸391 | Aug. 3, 2026 | Mari MennelBell-Bell | Oppose rescission | Individual | Modify / Expand ACCT CFR GHG12 GOV TARGETS FINSTMT |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: Modify / Expand — asks for stronger or broader disclosure Keep provisions: GHG12 (Scope 1 & 2 emissions), GOV (Governance / risk management), TARGETS (Targets / transition plan), FINSTMT (Financial-statement effects (Reg S-X Art. 14)) ACCT Stewardship / accountability — “Oversight of climate risks by company leadership” CFR Climate-related financial risk — “Certain financial effects connected to severe weather, flooding, drought, wildfires, extreme temperatures, sea-level rise, carbon offsets, and renewable energy credits.” | |||||
| ▸390 | Aug. 3, 2026 | Jacqueline Waldman | Oppose rescission | Individual | NR |
Position: Oppose rescission (majority) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework NR No substantive rationale — “We need this information!” | |||||
| ▸389 | Aug. 3, 2026 | Juanita Rinas | 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 — “account for severe-weather losses” ENV Environmental impact / consequences — “This proposal is a critical issue for environmental justice.” IP Investor protection / decision usefulness — “Climate disclosures help investors and the public understand how companies identify significant climate risks” | |||||
| ▸388 | Aug. 3, 2026 | Deborah Bruner | Oppose rescission | Individual | Modify / Expand CFR ENV IP |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: Modify / Expand — asks for stronger or broader disclosure CFR Climate-related financial risk — “account for severe-weather losses” ENV Environmental impact / consequences — “This proposal is a critical issue for environmental justice communities.” IP Investor protection / decision usefulness — “Climate disclosures can help investors and the public understand how companies identify significant climate risks” | |||||
| ▸387 | Aug. 3, 2026 | Kristen Fillmore | Oppose rescission | Individual | CMP ENV IP |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework CMP Standardization / comparability — “make significant climate-related information more consistent, comparable, and accessible” ENV Environmental impact / consequences — “Communities would lose a critical public source of environmental data.” IP Investor protection / decision usefulness — “provide investors with information about material climate-related risks in registration statements and annual reports” | |||||
| ▸386 | Aug. 3, 2026 | Barbara Douma | No position | Individual | |
Position: No position (unanimous) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework No coded rationale. | |||||
| ▸385 | Aug. 3, 2026 | Luci Ungar | 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 that has affected our environment” | |||||
| ▸384 | Aug. 3, 2026 | Jacqueline Benster | Oppose rescission | Individual | CMP ENV IP |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework CMP Standardization / comparability — “make significant climate-related information more consistent, comparable, and accessible” ENV Environmental impact / consequences — “Communities would lose a critical public source of environmental data.” IP Investor protection / decision usefulness — “provide investors with information about climate-related risks in registration statements and annual reports” | |||||
| ▸383 | Aug. 3, 2026 | John Alden Thayer | 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 — “Capitalism is not only destroying democracy, it is destroying our planet as well” | |||||
| ▸382 | Aug. 3, 2026 | Lawrence Hannon | 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 — “Europe and Canada are currently battling massive fires and heat!!!” | |||||
| ▸381 | Aug. 3, 2026 | Meg Barnes | 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 — “account for severe-weather losses” ENV Environmental impact / consequences — “This proposal is a critical issue for environmental justice communities.” IP Investor protection / decision usefulness — “Climate disclosures can help investors and the public understand how companies identify significant climate risks, account for severe-weather losses, calculate certain emissions, and describe publicly announced climate targets.” | |||||
| ▸380 | Aug. 3, 2026 | James R. Breczinski | Oppose rescission | Individual | CAPFORM |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework CAPFORM Market efficiency / capital formation — “History has shown us time after time that loosening regulations always results in a crash and a depression.” | |||||
| ▸379 | Aug. 3, 2026 | Alexander Mouton | 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 | |||||
| ▸378 | Aug. 3, 2026 | J.E. Kirkbride | Oppose rescission | Individual | Modify / Expand ENV |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: Modify / Expand — asks for stronger or broader disclosure ENV Environmental impact / consequences — “Have you looked outside this summer?” | |||||
| ▸377 | Aug. 3, 2026 | Sheila Winston | 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 — “You don't care anything at all about the health of the planet or the American people on it.” | |||||
| ▸376 | Aug. 3, 2026 | Benjamin Van Winkle | Oppose rescission | Individual | Modify / Expand ACCT CFR CMP ENV FRAG IP GHG12 GOV TARGETS FINSTMT |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: Modify / Expand — asks for stronger or broader disclosure Keep provisions: GHG12 (Scope 1 & 2 emissions), GOV (Governance / risk management), TARGETS (Targets / transition plan), FINSTMT (Financial-statement effects (Reg S-X Art. 14)) ACCT Stewardship / accountability — “How a company identifies and manages material climate-related risks;” CFR Climate-related financial risk — “Climate-related risks that have materially affected or are reasonably likely to materially affect the company;” CMP Standardization / comparability — “make significant climate-related information more consistent, comparable, and accessible” ENV Environmental impact / consequences — “This proposal is a critical issue for environmental justice communities.” FRAG Regulatory fragmentation / multi-jurisdictional consistency — “state disclosure systems” IP Investor protection / decision usefulness — “Investors could instead be required to locate information across general SEC filings, voluntary sustainability reports, state disclosure systems, and other company materials.” | |||||
| ▸375 | Aug. 3, 2026 | Paula Morgan | No position | Individual | ENV |
Position: No position (unanimous) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework ENV Environmental impact / consequences — “Climate is setting the earth on fire.” | |||||
| ▸374 | Aug. 3, 2026 | D. Burn | Oppose rescission | Individual | Modify / Expand CMP ENV IP |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: Modify / Expand — asks for stronger or broader disclosure CMP Standardization / comparability — “make significant climate-related information more consistent, comparable, and accessible” ENV Environmental impact / consequences — “Communities would lose a critical public source of environmental data.” IP Investor protection / decision usefulness — “Investors could instead be required to locate information across general SEC filings, voluntary sustainability reports, state disclosure systems, and other company materials.” | |||||
| ▸373 | Aug. 3, 2026 | Lois Karasek | 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 — “companies to include their impact on climate and the environment in their SEC statements and annual reports” IP Investor protection / decision usefulness — “This information is essential for investors to make fully informed decisions and should not be withheld from the public.” | |||||
| ▸372 | Aug. 3, 2026 | Debra Syevens | 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 — “should not be left to the good graces of corporations and what they choose to disclose voluntarily” ENV Environmental impact / consequences — “The degradation of our air and water and climate stability is already at risk due to lack of strict regulation” | |||||
| ▸371 | Aug. 3, 2026 | Judy Sophianopoulos | 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 | |||||
| ▸370 | Aug. 3, 2026 | Stephen Martin | 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 — “Citizens and investors should have all the information concerning how any companies action will affect themselves, their community, the country or environment.” IP Investor protection / decision usefulness — “Citizens and investors should have all the information concerning how any companies action will affect themselves, their community, the country or environment.” | |||||
| ▸369 | Aug. 3, 2026 | Frederick Brown | Oppose rescission | Individual | Modify / Expand ENV |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: Modify / Expand — asks for stronger or broader disclosure ENV Environmental impact / consequences — “the planet is already on fire.” | |||||
| ▸368 | Aug. 3, 2026 | Douglas Estes | 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 — “As an investor, I need to know how climate change may impact the companies I plan on investing in.” | |||||
| ▸367 | Aug. 3, 2026 | Paul Sumption | 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 — “Please stop denying climate change!! Your job to protect people after all!!” | |||||
| ▸366 | Aug. 3, 2026 | W. Runyon | Oppose rescission | Individual | Modify / Expand CMP ENV IP |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: Modify / Expand — asks for stronger or broader disclosure CMP Standardization / comparability — “make significant climate-related information more consistent, comparable, and accessible” ENV Environmental impact / consequences — “Communities would lose a critical public source of environmental data.” IP Investor protection / decision usefulness — “Investors could instead be required to locate information across general SEC filings, voluntary sustainability reports, state disclosure systems, and other company materials.” | |||||
| ▸365 | Aug. 3, 2026 | Committee on Corporate Reporting, FEI | Support rescission | Business trade association / advocacy org | Fallback / Compromise CAPFORM CB CBA CMP DEMAND FRAG IMMAT IP REDUN |
Position: Support rescission (unanimous) · Entity: Business trade association / advocacy org (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 Commission's focus on the Supreme Court's definition of materiality, disclosure rationalization and enhanced capital formation.” CB Compliance burden — “the costs of producing the information required by the final rule – in terms of systems investment, process development, SOX-compliant controls, and third-party assurance – would outweigh the benefit to stakeholders” CBA Cost-benefit assessment — “would outweigh the benefit to stakeholders, particularly given the large volume of climate-related information available through other sustainability reporting regimes.” CMP Standardization / comparability — “were neither operable nor likely to result in comparable data across peer issuers” DEMAND Investor demand / fund reliance — “We believe marketplace demand will continue to drive and ensure the availability of decision-useful climate data to market participants.” FRAG Regulatory fragmentation / multi-jurisdictional consistency — “CCR members are in scope of the European Union's Corporate Sustainability Reporting Directive ("CSRD").” IMMAT Immaterial / not decision-useful — “these mechanisms result in the disclosure of immaterial information, which runs counter to the Commission's focus on the Supreme Court's definition of materiality” IP Investor protection / decision usefulness — “Requiring disclosure beyond what a reasonable investor would consider important in making an investment or voting decision produces voluminous filings that can obscure rather than illuminate what is significant.” REDUN Redundant — existing rules, materiality regime, or voluntary reporting already suffice — “CCR believes that the existing SEC disclosure framework already provides a meaningful mechanism for communicating material climate-related developments.” | |||||
| ▸364 | Aug. 3, 2026 | Sarah McVay, Professor of Accounting, University of Washington | Oppose rescission | Academic researcher | Modify / Expand CFR INSUFF IP PP |
Position: Oppose rescission (unanimous) · Entity: Academic researcher (unanimous) Modification posture: Modify / Expand — asks for stronger or broader disclosure CFR Climate-related financial risk — “Climate-related risks are one example of a broader class of sustainability-related risks that affect profit durability.” INSUFF Insufficient / incoherent legal basis (either direction) — “the current proposal does not appear to provide a reasonable or fair balance between capital formation and investor protection objectives” IP Investor protection / decision usefulness — “Investors need sufficient information to assess not only the level of a company's profits, but also the durability of those profits.” PP Political pressure / regulatory capture — “Only three of the five commissioner seats are filled, creating a sharp imbalance in representation.” | |||||
| ▸363 | Aug. 3, 2026 | Treasurer Michael Frerichs, Office of the Illinois Treasurer | Oppose rescission | Government / elected official | ACCT CBA CFR CMP DEMAND FRAG IP |
Position: Oppose rescission (unanimous) · Entity: Government / elected official (majority) Modification posture: No modification requested — no substantive request to change the framework ACCT Stewardship / accountability — “that may have a material impact on performance.8 My office may vote against directors” CBA Cost-benefit assessment — “qualitative information. This will drive efficiencies in the market and save investors money” CFR Climate-related financial risk — “Climate change poses a material risk to our investments and portfolio” CMP Standardization / comparability — “The lack of consistent, comparable, and standardized disclosures on material climate-related” DEMAND Investor demand / fund reliance — “investors overwhelmingly favored the SEC” FRAG Regulatory fragmentation / multi-jurisdictional consistency — “disclosure law requires companies with over $1 billion in revenue to report their greenhouse” IP Investor protection / decision usefulness — “clear, consistent, and decision‑useful information that we would use to assess material financial risks” | |||||
| ▸362 | Aug. 3, 2026 | Jeremy Weinstein | Support rescission | Individual | AUTH CAPFORM CB CBA FRAG INSUFF PP |
Position: Support rescission (unanimous) · Entity: Individual (majority) Modification posture: No modification requested — no substantive request to change the framework AUTH Statutory authority / major-questions (either direction) — “It should not replace its judgment for that of state and federal regulators” CAPFORM Market efficiency / capital formation — “incentivize directing loans to those with lower emissions over those with higher emissions, even” CB Compliance burden — “that recission would avoid include liability for mistakes by CPAs hitherto not in the business of” CBA Cost-benefit assessment — “administrative agencies. And all for nought: there is no evidence that mandatory corporate” FRAG Regulatory fragmentation / multi-jurisdictional consistency — “regulators create robust definitions to obtain high quality compliance for their programs.” INSUFF Insufficient / incoherent legal basis (either direction) — “One arbitrary and capricious Rule provision was not even in the Proposed Rule” PP Political pressure / regulatory capture — “avenged being thwarted earlier. But the SEC should not be the keeper of federal environmental” | |||||
| ▸361 | Aug. 3, 2026 | Michael Buschbacher, Managing Partner, Boyden Gray PLLC | Support rescission | Legal practitioner | 1A ACCT AUTH CAPFORM CB CBA CMP ENV IMMAT INSUFF PP 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) — “The proposed rule would violate the First Amendment by compelling controversial speech.” ACCT Stewardship / accountability — “may be making voting and investment decisions based on their own self-interest rather than in the interest of the funds they manage” AUTH Statutory authority / major-questions (either direction) — “The SEC lacks statutory authority to issue its proposed rule mandating vast climate disclosures” CAPFORM Market efficiency / capital formation — “Not in the Public Interest: Undercuts Capital Formation.” CB Compliance burden — “are around $15.3 billion, with over $3.5 billion of that in the first year alone” CBA Cost-benefit assessment — “we think the Commission has not sufficiently supported its conclusion” CMP Standardization / comparability — “it is unclear what valuable information exists that could be meaningfully compared firm to firm in the same industry” ENV Environmental impact / consequences — “there is great uncertainty in the magnitude and timescale of this temperature increase” IMMAT Immaterial / not decision-useful — “the information sought by the proposed rule is not material for a variety of reasons” INSUFF Insufficient / incoherent legal basis (either direction) — “The proposed rule would be arbitrary and capricious for more than a dozen reasons, not least of which being that it encourages substantial conflicts of interest and is based on gross misrepresentations of the facts of climate change.” PP Political pressure / regulatory capture — “The proposed rule is a glaringly clear example of pay-to-play politics and self-dealing.” REDUN Redundant — existing rules, materiality regime, or voluntary reporting already suffice — “Companies are already disclosing some climate-related information as it could be responsive to several existing disclosure requirements” | |||||
| ▸360 | Aug. 3, 2026 | Anne Bradbury, Chief Executive Officer, American Exploration and Production Council | Support rescission | Business trade association / advocacy org | AUTH CAPFORM CB CBA FRAG IMMAT IP REDUN |
Position: Support rescission (unanimous) · Entity: Business trade association / advocacy org (unanimous) Modification posture: No modification requested — no substantive request to change the framework AUTH Statutory authority / major-questions (either direction) — “but that role must be exercised within the Commission's statutory authority and” CAPFORM Market efficiency / capital formation — “could have discouraged public company status altogether” CB Compliance burden — “They would have required substantially all registrants to build new reporting systems,” CBA Cost-benefit assessment — “should be justified by the benefits the information provides. The Final Rules failed that test.” FRAG Regulatory fragmentation / multi-jurisdictional consistency — “registrants to maintain duplicative” IMMAT Immaterial / not decision-useful — “this approach risked elevating climate-related” IP Investor protection / decision usefulness — “better serves investors by focusing their attention on the information that actually bears on” REDUN Redundant — existing rules, materiality regime, or voluntary reporting already suffice — “information was already, and remains, available to investors through numerous channels” | |||||
| ▸359 | Aug. 3, 2026 | Kathy Fallon, Land Systems Program Director, Rebecca Sanders-DeMott, Director, Ecosystem Carbon Science, Mary Sasso, Attorney, Frank Sturges, Senior Attorney, Clean Air Task Force | Oppose rescission | Environmental / ESG advocacy org | ACCT AUTH CFR CMP DEMAND FRAG INSUFF IP FINSTMT |
Position: Oppose rescission (unanimous) · Entity: Environmental / ESG advocacy org (unanimous) Modification posture: No modification requested — no substantive request to change the framework Keep provisions: FINSTMT (Financial-statement effects (Reg S-X Art. 14)) ACCT Stewardship / accountability — “reputational risk is accusations of "greenwashing," which is generally understood as falsely” AUTH Statutory authority / major-questions (either direction) — “the Climate-Related Disclosure Rules are clearly within the” CFR Climate-related financial risk — “Companies face financial risk from expenditures on carbon offsets.” CMP Standardization / comparability — “availability of consistent, comparable, and transparent information on emissions, including” DEMAND Investor demand / fund reliance — “companies and investors weighed in on the importance of the SEC requiring consistent and” FRAG Regulatory fragmentation / multi-jurisdictional consistency — “California's Cap-and-Invest Program permits regulated entities” INSUFF Insufficient / incoherent legal basis (either direction) — “is therefore not the product of reasoned decision making, is arbitrary and capricious, and must be” IP Investor protection / decision usefulness — “This information is material to investors, and its disclosure” | |||||
| ▸358 | Aug. 3, 2026 | Rose Oswald Poels, President/CEO, Wisconsin Bankers Association | Support rescission | Business trade association / advocacy org | Fallback / Compromise AUTH CAPFORM CB CFR FRAG IMMAT PP REDUN |
Position: Support rescission (unanimous) · Entity: Business trade association / advocacy org (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) — “questioning the true authority of SEC to require the proposed climate-risk related content” CAPFORM Market efficiency / capital formation — “Such reallocation of capital and banking relationships is harmful to the overall economy and” CB Compliance burden — “WBA members have reported SEC's proposal would impose incredible costs to implement.” CFR Climate-related financial risk — “including how climate may impact those long-standing” FRAG Regulatory fragmentation / multi-jurisdictional consistency — “or future prudential regulation of financial institutions and must be coordinated with prudential” IMMAT Immaterial / not decision-useful — “Climate-related issues, including emission of greenhouse gases, are not” PP Political pressure / regulatory capture — “climate-related disclosures is to promote non-financial, social agendas. WBA cautions against” REDUN Redundant — existing rules, materiality regime, or voluntary reporting already suffice — “WBA believes current SEC regulatory disclosure rules and guidance already require or” | |||||
| ▸357 | Aug. 3, 2026 | Erick Russell, Treasurer, Connecticut Retirement Plans and Trust Funds | Oppose rescission | Government / elected official | ACCT CAPFORM CFR CMP IP |
Position: Oppose rescission (unanimous) · Entity: Government / elected official (majority) Modification posture: No modification requested — no substantive request to change the framework ACCT Stewardship / accountability — “proven to be an effective strategy for holding boards accountable for their oversight of climate risks” CAPFORM Market efficiency / capital formation — “reduces comparability, but increases analytical burdens, and ultimately diminishes the efficiency of” CFR Climate-related financial risk — “Climate-related risks increasingly have measurable financial consequences for companies and” CMP Standardization / comparability — “face inconsistent reporting across issuers, limiting the ability to compare companies within industries,” IP Investor protection / decision usefulness — “ability to fulfill our fiduciary obligations depends upon access to reliable information that enables” | |||||
| ▸356 | Aug. 3, 2026 | Lesley Brill | 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 — “I STRONGLY OPPOSE the disgraceful Rescission of Climate-Related Disclosure Rules now being considered by the US Securities and Exchange Commission.” | |||||
| ▸355 | Aug. 3, 2026 | Jenna Burke, EVP, General Counsel, Government Relations, Independent Community Bankers of America | Support rescission | Business trade association / advocacy org | AUTH CB CFR INSUFF PP |
Position: Support rescission (unanimous) · Entity: Business trade association / advocacy org (unanimous) Modification posture: No modification requested — no substantive request to change the framework AUTH Statutory authority / major-questions (either direction) — “II. The 2024 final rule exceeded the SEC's statutory authority.” CB Compliance burden — “by the 2024 final rule are untenable for community bank registrants to manage and will discourage community” CFR Climate-related financial risk — “the 2024 final rule paradoxically accelerates the same transition risks the SEC seeks to avoid.” INSUFF Insufficient / incoherent legal basis (either direction) — “III. The 2024 final rule was not based on reasoned decision-making.” PP Political pressure / regulatory capture — “oversight and climate disclosure enforcement is legally questionable, appears to be politically motivated, and” | |||||
| ▸354 | Aug. 3, 2026 | Lorna Wood | Oppose rescission | Individual | ACCT CFR ENV IP |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework ACCT Stewardship / accountability — “establishing accountability among publicly traded companies” CFR Climate-related financial risk — “information about material climate-related risks in registration statements and annual reports” ENV Environmental impact / consequences — “our civilization teeters on the brink of catastrophic climate-related destruction” IP Investor protection / decision usefulness — “provide investors with information about material climate-related risks in registration statements and annual reports” | |||||
| ▸353 | Aug. 3, 2026 | Mary Ellen Strand | Oppose rescission | Individual | CMP ENV IP |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework CMP Standardization / comparability — “make significant climate-related information more consistent, comparable, and accessible” ENV Environmental impact / consequences — “How can anyone seeing the impact wildfires and heat are having on our country and our planet think that losing critical public environmental data is a good idea?” IP Investor protection / decision usefulness — “Investors could instead be required to locate information across general SEC filings, voluntary sustainability reports, state disclosure systems, and other company materials.” | |||||
| ▸352 | Aug. 3, 2026 | Wilbur Ince | Oppose rescission | Individual | CMP IP |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework CMP Standardization / comparability — “make significant climate-related information more consistent, comparable, and accessible” IP Investor protection / decision usefulness — “Investors could instead be required to locate information across general SEC filings, voluntary sustainability reports, state disclosure systems, and other company materials.” | |||||
| ▸351 | Aug. 3, 2026 | Connie Haack | Oppose rescission | Individual | Modify / Expand NR |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: Modify / Expand — asks for stronger or broader disclosure NR No substantive rationale — “Rules need to be stronger not weaker” | |||||
| ▸350 | Aug. 3, 2026 | Gay Jurgens | 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 — “Environmental threats from climate change are real and would be respected.” | |||||
| ▸349 | Aug. 3, 2026 | Jared Leavitt | No position | Individual | |
Position: No position (unanimous) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework No coded rationale. | |||||
| ▸348 | Aug. 3, 2026 | Lauren Linda | 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 — “how companies identify significant climate risks, account for severe-weather losses” ENV Environmental impact / consequences — “Public companies own and operate fossil fuel, petrochemical, utility, transportation, manufacturing, housing, insurance, and financial assets in communities across the country.” IP Investor protection / decision usefulness — “Climate disclosures can help investors and the public understand how companies identify significant climate risks, account for severe-weather losses, calculate certain emissions, and describe publicly announced climate targets.” | |||||
| ▸347 | Aug. 3, 2026 | Michaele Tharrett | 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 — “I disagree with rescinding this very important disclosure rule.” | |||||
| ▸346 | Aug. 3, 2026 | Joseph V. Amato, President and Chief Investment Officer, Equities and Jonathan Bailey, Global Head of Stewardship & Sustainable Investing, Neuberger | Oppose rescission | Investor / asset manager (institutional) | Fallback / Compromise CBA CFR CMP DEMAND FRAG INSUFF IP WHIP GHG12 |
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) CBA Cost-benefit assessment — “We have concerns about the rigor and balance of the cost-benefit analysis ("CBA") underpinning” CFR Climate-related financial risk — “decision-useful disclosure of financially material risks, including climate-related risks, is” CMP Standardization / comparability — “mandatory disclosure frameworks improve comparability and quality of this disclosure.” DEMAND Investor demand / fund reliance — “v. Mischaracterization of Investor Demand as a "Subgroup"” FRAG Regulatory fragmentation / multi-jurisdictional consistency — “regardless of the SEC's rules. CARB's Preliminary List of Reporting/Covered Entities identifies” INSUFF Insufficient / incoherent legal basis (either direction) — “difficult to reconcile; the economic baseline (with the rules in effect) is used to generate the total” IP Investor protection / decision usefulness — “foundational to our ability to analyze investment risks and opportunities, and allocate our clients'” WHIP Regulatory whiplash / reliance interests / costs already incurred — “and reporting infrastructure in year ten should face costs well below those incurred in year two;” | |||||
| ▸345 | Aug. 3, 2026 | Robin Hicks | Oppose rescission | Individual | Modify / Expand CMP ENV IP |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: Modify / Expand — asks for stronger or broader disclosure CMP Standardization / comparability — “more consistent, comparable, and accessible” ENV Environmental impact / consequences — “Communities would lose a critical public source of environmental data.” IP Investor protection / decision usefulness — “Investors could instead be required to locate information across general SEC filings, voluntary sustainability reports, state disclosure systems, and other company materials.” | |||||
| ▸344 | Aug. 3, 2026 | Carl Carnein | 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 — “some corporations try to obfuscate and shirk their responsibilities” ENV Environmental impact / consequences — “The climate crisis isn't going away, despite Republicans' wishful thinking to the contrary.” IP Investor protection / decision usefulness — “I believe I have the right to easy access to information that would allow me to make easy choices about my investments and my purchases.” | |||||
| ▸343 | Aug. 3, 2026 | Senator Sheldon Whitehouse, Ranking Member Committee on Environment and Public Works and Senator Elizabeth Warren, Ranking Member Committee on Banking, Housing, and Urban Affairs | Oppose rescission | Government / elected official | ACCT AUTH CAPFORM CBA CFR CMP DEMAND FRAG INSUFF IP PP |
Position: Oppose rescission (unanimous) · Entity: Government / elected official (unanimous) Modification posture: No modification requested — no substantive request to change the framework ACCT Stewardship / accountability — “the final rules will leave investors with no corresponding standardized mechanism to verify” AUTH Statutory authority / major-questions (either direction) — “The Commission argued that it lacked the statutory authority, under the Securities Act of 1933” CAPFORM Market efficiency / capital formation — “leave U.S. capital markets increasingly fragmented and out of step with an accelerating global” CBA Cost-benefit assessment — “Rescinding the final rules will not spare large companies the underlying cost of producing the” CFR Climate-related financial risk — “Climate Change Poses Material, Escalating, and Systemic Financial Risk” CMP Standardization / comparability — “yardstick is what lets investors compare climate risk across companies in the first place, rather” DEMAND Investor demand / fund reliance — “roughly three-quarters believe standardized, mandatory reporting is” FRAG Regulatory fragmentation / multi-jurisdictional consistency — “California's Climate Corporate Data Accountability Act (SB 253) remains in effect and requires” INSUFF Insufficient / incoherent legal basis (either direction) — “rests on a legal theory that mischaracterizes both the final rules and the Commission's own” IP Investor protection / decision usefulness — “repeatedly and unambiguously, that they need to price and manage risk.” PP Political pressure / regulatory capture — “as this administration pursues rollbacks of other disclosure rules.” | |||||
| ▸342 | Aug. 3, 2026 | B. Aronson | 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 — “CONCERNED ABOUT CLIMATE ISSUES” IP Investor protection / decision usefulness — “I RELY ON COMPANIES PUBLICIZING THEIR POSITIONS.” | |||||
| ▸341 | Aug. 3, 2026 | A. M. Shanahan | Oppose rescission | Individual | Modify / Expand NR |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: Modify / Expand — asks for stronger or broader disclosure NR No substantive rationale | |||||
| ▸340 | Aug. 3, 2026 | Cindy Burkhardt | 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 — “Please don't destroy life on our planet.” | |||||
| ▸339 | Aug. 3, 2026 | Michael Wood | Oppose rescission | Individual | Modify / Expand ENV |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: Modify / Expand — asks for stronger or broader disclosure ENV Environmental impact / consequences — “Rescinding the rules will lead to harmful implications, nationwide.” | |||||
| ▸338 | Aug. 3, 2026 | Davis Diehl | Oppose rescission | Individual | Modify / Expand CMP ENV IP |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: Modify / Expand — asks for stronger or broader disclosure CMP Standardization / comparability — “more consistent, comparable, and accessible” ENV Environmental impact / consequences — “Our world is burning. Flooding. Storms are increasing in strength and frequency.” IP Investor protection / decision usefulness — “Investors could instead be required to locate information across general SEC filings, voluntary sustainability reports, state disclosure systems, and other company materials.” | |||||
| ▸337 | Aug. 3, 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 — “Stop this administration from killing our planet and everything on it” | |||||
| ▸336 | Aug. 3, 2026 | Cassie Paul | Oppose rescission | Individual | CMP ENV IP |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework CMP Standardization / comparability — “more consistent, comparable, and accessible” ENV Environmental impact / consequences — “Communities would lose a critical public source of environmental data.” IP Investor protection / decision usefulness — “Investors could instead be required to locate information across general SEC filings, voluntary sustainability reports, state disclosure systems, and other company materials.” | |||||
| ▸335 | Aug. 3, 2026 | Laura Harper | Oppose rescission | Individual | CFR CMP 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 — “identify significant climate risks, account for severe-weather losses” CMP Standardization / comparability — “makes significant climate-related information more consistent, comparable, and accessible” ENV Environmental impact / consequences — “Eliminating the framework would deprive communities of a critical public source of environmental data” IP Investor protection / decision usefulness — “Climate disclosures can help investors and the public understand how companies identify significant climate risks, account for severe-weather losses, calculate certain emissions, and describe publicly announced climate targets.” | |||||
| ▸334 | Aug. 3, 2026 | Environmental Defense Fund, Clean Air Task Force, Earthjustice, Natural Resources Defense Council, and Sierra Club | Oppose rescission | Environmental / ESG advocacy org | ACCT AUTH CAPFORM CB CBA CFR CMP DEMAND FRAG INSUFF IP WHIP |
Position: Oppose rescission (unanimous) · Entity: Environmental / ESG advocacy org (unanimous) Modification posture: No modification requested — no substantive request to change the framework ACCT Stewardship / accountability — “registrants providing only "boilerplate" information or "greenwashing."” AUTH Statutory authority / major-questions (either direction) — “The Disclosure Rules Are Well Within the Commission's Authority.” CAPFORM Market efficiency / capital formation — “critical for investor protection, market efficiency and capital formation” CB Compliance burden — “These costs amount to the hiring of at most a handful of additional employees (and as few as a single one) per company to handle reporting obligations.” CBA Cost-benefit assessment — “The Disclosure Rules' Costs Are Reasonable and the Rules Deliver Large Informational Benefits, Which the Proposal All But Ignores.” CFR Climate-related financial risk — “Climate-related physical risks can affect a company's business activities and its current and longer-term financial performance by damaging assets, disrupting operations, and increasing costs.” CMP Standardization / comparability — “Investors benefit from being able to compare disclosed information between entities, apples to apples.” DEMAND Investor demand / fund reliance — “make it easier for [their] investment staff to assess a company's individual risk from climate change and evaluate the financial impacts.” FRAG Regulatory fragmentation / multi-jurisdictional consistency — “Other jurisdictions' cross-sectoral climate risk disclosure requirements—including those of California, the European Union's Corporate Sustainability Reporting Directive (CSRD), and the International Sustainability Standards Board (ISSB)—are more akin to the Disclosure Rules” INSUFF Insufficient / incoherent legal basis (either direction) — “The Proposal Is Arbitrary and Capricious and an Inadequately Explained Change in Position.” IP Investor protection / decision usefulness — “investors need disclosure of climate risks that is complete, reliable, and consistent in order to analyze how climate-related risks may affect a company's business or overall financial performance” WHIP Regulatory whiplash / reliance interests / costs already incurred — “Those companies are making or have already made investments in climate data collection and reporting that will drastically reduce the cost of complying with the SEC obligations.” | |||||
| ▸333 | Aug. 3, 2026 | Susan H. Dewey | 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 — “the public should be aware of how corporations are dealing with it or NOT dealing with it” ENV Environmental impact / consequences — “As the western States burn and the east is dealing with floods putting our head in the sand is NOT an option.” | |||||
| ▸332 | Aug. 3, 2026 | Michael Levine, V.P. & Assistant General Counsel and Erin Hiatt, S.V.P., Retail Operations, Retail Industry Leaders Association | Support rescission | Business trade association / advocacy org | AUTH CB CBA CMP FRAG IMMAT INSUFF REDUN |
Position: Support rescission (unanimous) · Entity: Business trade association / advocacy org (unanimous) Modification posture: No modification requested — no substantive request to change the framework AUTH Statutory authority / major-questions (either direction) — “are focused on highlighting RILA's prior comments about legal/statutory authority issues posed” CB Compliance burden — “First, reporting scope 3 emissions with accuracy and precision poses extraordinary challenges for” CBA Cost-benefit assessment — “A climate-specific overlay would add cost and complexity without a retail industry” CMP Standardization / comparability — “companies to significant liability risks and produce estimates that appear, but are not,” FRAG Regulatory fragmentation / multi-jurisdictional consistency — “California has enacted SB 253, SB 261, and AB 1305.” IMMAT Immaterial / not decision-useful — “immaterial, speculative, or non-comparable climate information does not.” INSUFF Insufficient / incoherent legal basis (either direction) — “particular circumstances, the federal securities laws do not require, and the administrative record” REDUN Redundant — existing rules, materiality regime, or voluntary reporting already suffice — “securities-law materiality. Existing rules already require disclosure of material climate” | |||||
| ▸331 | Aug. 3, 2026 | Tynesia Boyea-Robinson, Chair, Board of Directors, Freedom Economy Business Association | Oppose rescission | Environmental / ESG advocacy org | ACCT AUTH CFR CMP DEMAND ENV INSUFF IP GOV |
Position: Oppose rescission (unanimous) · Entity: Environmental / ESG advocacy org (majority) Modification posture: No modification requested — no substantive request to change the framework Keep provisions: GOV (Governance / risk management) ACCT Stewardship / accountability — “disclose board oversight of climate-related risks. Rescinding this requirement removes a” AUTH Statutory authority / major-questions (either direction) — “disclosure areas. By arguing that SEC mandates must strictly adhere to Schedule A⁵ of” CFR Climate-related financial risk — “and regulatory compliance costs, deeply impact long-term corporate valuation.” CMP Standardization / comparability — “transparency by denying investors access to standardized, comparable data.” DEMAND Investor demand / fund reliance — “Investors have been calling for increased disclosure and regulation around” ENV Environmental impact / consequences — “The growing occurrence and cost of large climate-related disasters will put significant” INSUFF Insufficient / incoherent legal basis (either direction) — “By moving away from qualitative risk factors, the Commission discards decades of” IP Investor protection / decision usefulness — “explicitly recognizes that qualitative factors are vital to the information a reasonable” | |||||
| ▸330 | Aug. 3, 2026 | Roberto Thornton, Co-Chief Executive Officer, Adasina Social Capital | Oppose rescission | Investor / asset manager (institutional) | CFR CMP DEMAND INSUFF 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 — “evaluate companies' exposure to climate risks.” CMP Standardization / comparability — “would undermine our ability to obtain comparable, consistent, and standardized disclosures of material,” DEMAND Investor demand / fund reliance — “but the record established strong investor demand for climate risk disclosure rules and” INSUFF Insufficient / incoherent legal basis (either direction) — “We also believe the rescission proposal mischaracterizes the rulemaking record.” IP Investor protection / decision usefulness — “This would impede Adasina's investment decision-making and portfolio” | |||||
| ▸329 | Aug. 3, 2026 | Jaime Klima, General Counsel, NYSE Group | Support rescission | Business trade association / advocacy org | CAPFORM CB CBA IMMAT REDUN |
Position: Support rescission (unanimous) · Entity: Business trade association / advocacy org (unanimous) Modification posture: No modification requested — no substantive request to change the framework CAPFORM Market efficiency / capital formation — “The Value of Advancing the Commission's Broader Capital Formation Agenda” CB Compliance burden — “Recently, the Commission has prioritized reducing the regulatory burden of being a public company,” CBA Cost-benefit assessment — “when the expected benefits justify the likely costs and burdens” IMMAT Immaterial / not decision-useful — “required the disclosure of non-material information, as materiality has long been understood for” REDUN Redundant — existing rules, materiality regime, or voluntary reporting already suffice — “Notably, even if the Climate Disclosure Rules are rescinded, disclosure of climate-related information” | |||||
| ▸328 | Aug. 3, 2026 | Russell Greene, Executive Director, Prime Mover Institute | Support rescission | Business trade association / advocacy org | 1A AUTH CB CBA IMMAT PP REDUN |
Position: Support rescission (unanimous) · Entity: Business trade association / advocacy org (majority) Modification posture: No modification requested — no substantive request to change the framework 1A Compelled speech / First Amendment (either direction) — “The SEC should fully rescind the Disclosure Rules because they are an affront to the First Amendment” AUTH Statutory authority / major-questions (either direction) — “The Disclosure Rules are also doomed by their lack of statutory authority. The SEC is a creature of statute, and it may act only within the authority Congress provided it.” CB Compliance burden — “The Disclosure Rules are also financially burdensome, with an estimated cost of "$4.9 billion per year over the next 10 years."” CBA Cost-benefit assessment — “Considering the lack of any return on that cost, the financial burden is another reason to rescind the Rules.” IMMAT Immaterial / not decision-useful — “By requiring disclosure of speculative and immaterial information, the Disclosure Rules risk obscuring truly material information in a registrant's report.” PP Political pressure / regulatory capture — “Rather than serving a compelling government interest, the Disclosure Rules were issued to satisfy a political promise about climate-change policy.” REDUN Redundant — existing rules, materiality regime, or voluntary reporting already suffice — “Registrants must already disclose material financial information, including impacts from regulations and legislation, and mandating additional disclosures is excessive.” | |||||
| ▸327 | Aug. 3, 2026 | Business Roundtable | Support rescission | Business trade association / advocacy org | ACCT AUTH CAPFORM CB CBA FRAG IMMAT INSUFF IP REDUN |
Position: Support rescission (unanimous) · Entity: Business trade association / advocacy org (unanimous) Modification posture: No modification requested — no substantive request to change the framework ACCT Stewardship / accountability — “The Rules required extensive disclosure regarding board oversight processes, committee responsibilities, management expertise, and internal governance structures.” AUTH Statutory authority / major-questions (either direction) — “The Rules represented a significant expansion of the Commission's disclosure requirements into an area of substantial economic and political significance and raised serious questions regarding the Commission's statutory authority” CAPFORM Market efficiency / capital formation — “may further disincentivize private companies from accessing the U.S. public markets.” CB Compliance burden — “Compliance with the Rules would have required substantial ongoing expenditures for data collection, governance, processes, disclosure controls, legal review and reporting systems.” CBA Cost-benefit assessment — “The Commission acknowledged significant challenges in quantifying the Rules' benefits but nevertheless failed to demonstrate that those benefits justified the substantial costs the Rules would impose.” FRAG Regulatory fragmentation / multi-jurisdictional consistency — “These compliance burdens would have been layered on top of an already complicated and increasingly fragmented landscape of state and international climate reporting requirements that companies already navigate, creating further complexity and duplicative reporting.” IMMAT Immaterial / not decision-useful — “required extensive disclosures, in many cases regardless of whether the underlying information was material to investors.” INSUFF Insufficient / incoherent legal basis (either direction) — “Nor did the Commission adequately evaluate the Rules' effects on efficiency, competition, and capital formation in light of the existing disclosure framework, as required under the federal securities laws.” IP Investor protection / decision usefulness — “Whether a company is evaluating geopolitical developments, supply-chain disruptions, technological change, or climate-related matters, disclosure should be required only to the extent the information is material to a reasonable investor.” REDUN Redundant — existing rules, materiality regime, or voluntary reporting already suffice — “Federal securities laws already require registrants to disclose material risks, which may include climate-related risks where applicable, through the existing disclosure framework without the need for a separate, prescriptive disclosure regime.” | |||||
| ▸326 | Aug. 3, 2026 | Dustin Meyer, Senior Vice President, Policy, Economics & Regulatory Affairs, American Petroleum Institute | Support rescission | Business trade association / advocacy org | 1A ACCT AUTH CAPFORM CB CBA FRAG IMMAT INSUFF IP REDUN |
Position: Support rescission (unanimous) · Entity: Business trade association / advocacy org (unanimous) Modification posture: No modification requested — no substantive request to change the framework 1A Compelled speech / First Amendment (either direction) — “Compelled disclosure of opinions, projections, and contested methodological conclusions, rather than verifiable facts within an issuer's own knowledge, implicates the First Amendment right against compelled speech.” ACCT Stewardship / accountability — “By requiring every issuer to disclose the board's oversight of climate-related risk, regardless of whether climate risk was material to that issuer's business, the Final Rules singled out one risk category for mandatory board-level attention” AUTH Statutory authority / major-questions (either direction) — “The federal securities laws authorize the Commission to require disclosure of information necessary for investors to make informed investment and voting decisions. They do not authorize the Commission to require disclosure of information for environmental policy purposes” CAPFORM Market efficiency / capital formation — “difficult to reconcile with the Commission's statutory obligation to consider whether its rules promote efficiency, competition, and capital formation, as well as its broader mission to maintain fair, orderly and efficient markets.” CB Compliance burden — “A mandatory climate-disclosure regime would have required many issuers to build or procure new data-collection, measurement, and verification infrastructure.” CBA Cost-benefit assessment — “The Proposal estimates that full rescission will produce annualized savings of approximately $4.9 billion per year over a ten-year period.” FRAG Regulatory fragmentation / multi-jurisdictional consistency — “In February 2026, the EU adopted legislation removing approximately eighty percent of previously covered companies from the scope of the CSRD and extending implementation timelines for the remainder.” IMMAT Immaterial / not decision-useful — “The cumulative effect of these departures from materiality was to bury investors in an avalanche of climate-related data of limited decision-making value.” INSUFF Insufficient / incoherent legal basis (either direction) — “The integrated structure of the Final Rules reinforces this conclusion. The Final Rules do not consist of severable, freestanding requirements that can be individually retained or discarded.” IP Investor protection / decision usefulness — “The reasonable investor evaluates information because it bears on the value, risk, governance, or expected return of the security, not as a vehicle for advancing esoteric or even generalized preferences.” REDUN Redundant — existing rules, materiality regime, or voluntary reporting already suffice — “Four existing Regulation S-K items collectively address the full range of material climate-related information.” | |||||
| ▸325 | Aug. 3, 2026 | Mike Flood, Senior Vice President, Center for Capital Markets Competitiveness, U.S. Chamber of Commerce | Support rescission | Business trade association / advocacy org | 1A AUTH CAPFORM CB CBA FRAG IMMAT INSUFF IP REDUN |
Position: Support rescission (unanimous) · Entity: Business trade association / advocacy org (unanimous) Modification posture: No modification requested — no substantive request to change the framework 1A Compelled speech / First Amendment (either direction) — “The rule also raised serious First Amendment concerns. It would compel companies to speak on climate change, a matter of contested public concern” AUTH Statutory authority / major-questions (either direction) — “Congress authorized the SEC to require disclosures tied to registrants' business and financial condition and to information material to investment and voting decisions.” CAPFORM Market efficiency / capital formation — “The securities laws require the Commission to consider whether a rule will promote efficiency, competition, and capital formation” CB Compliance burden — “governance-distortion costs, audit and assurance costs, economy-wide costs, and costs imposed indirectly on private companies.” CBA Cost-benefit assessment — “the climate rule is a costly solution to an unproven problem.” FRAG Regulatory fragmentation / multi-jurisdictional consistency — “California has likewise delayed implementation of its greenhouse-gas disclosure statute amidst questions about the law's scope and precise methodology.” IMMAT Immaterial / not decision-useful — “The Commission has repeatedly warned that excessive immaterial disclosures obscure important information and burden investors rather than protect them.” INSUFF Insufficient / incoherent legal basis (either direction) — “The arbitrary-and-capricious standard of the Administrative Procedure Act requires an agency to ground a change in settled policy in the rulemaking record” IP Investor protection / decision usefulness — “the reasonable investor would consider the information important in buying or selling securities” REDUN Redundant — existing rules, materiality regime, or voluntary reporting already suffice — “If a specific piece of climate-related information is material, existing rules already require it.” | |||||
| ▸324 | Aug. 3, 2026 | State Financial Officers Foundation | Support rescission | Government / elected official | AUTH CAPFORM CB CBA IMMAT IP REDUN |
Position: Support rescission (unanimous) · Entity: Government / elected official (unanimous) Modification posture: No modification requested — no substantive request to change the framework AUTH Statutory authority / major-questions (either direction) — “We agree with the Commission's conclusion that the Final Rules represented a "dramatic overreach" of its statutory authority.” CAPFORM Market efficiency / capital formation — “such costs are at odds with the Commission's statutory obligations to promote efficiency, competition, and capital formation, and with its objective of preserving the attractiveness of public-company status.” CB Compliance burden — “costs ultimately passed to shareholders, including the beneficiaries we serve.” CBA Cost-benefit assessment — “The Commission's own economic analysis estimates that rescinding the Final Rules could generate annualized savings of approximately $4.9 billion” IMMAT Immaterial / not decision-useful — “much of it immaterial to any particular registrant—exceeds the bounds Congress set.” IP Investor protection / decision usefulness — “protecting investors from being buried in an avalanche of trivial detail, and sparing registrants the cost of disclosing every minor operational fact.” REDUN Redundant — existing rules, materiality regime, or voluntary reporting already suffice — “The Final Rules are unnecessary. The Commission's longstanding, principles-based disclosure regime already requires a registrant to disclose climate-related matters when they are material to that specific company” | |||||
| ▸323 | Aug. 3, 2026 | U.S. Chamber of Commerce and 41 Trade Associations | Support rescission | Business trade association / advocacy org | 1A AUTH CB CBA CMP IMMAT INSUFF REDUN |
Position: Support rescission (unanimous) · Entity: Business trade association / advocacy org (unanimous) Modification posture: No modification requested — no substantive request to change the framework 1A Compelled speech / First Amendment (either direction) — “The rule also raised serious First Amendment concerns.” AUTH Statutory authority / major-questions (either direction) — “The federal securities laws do not authorize the Commission to impose a” CB Compliance burden — “the rule would cost far more than projected” CBA Cost-benefit assessment — “The asserted benefits fail across the board.” CMP Standardization / comparability — “Standardization also would not have produced reliable or comparable” IMMAT Immaterial / not decision-useful — “information that often would not be financially material” INSUFF Insufficient / incoherent legal basis (either direction) — “No reliance interest counsels partial retention.” REDUN Redundant — existing rules, materiality regime, or voluntary reporting already suffice — “Existing SEC rules already require disclosure of material” | |||||
| ▸322 | Aug. 3, 2026 | Michael Kramer, Manager & Trust Steward, Natural Investments PBLLC | Oppose rescission | Investor / asset manager (institutional) | AUTH CFR CMP IP |
Position: Oppose rescission (unanimous) · Entity: Investor / asset manager (institutional) (unanimous) Modification posture: No modification requested — no substantive request to change the framework AUTH Statutory authority / major-questions (either direction) — “The standard for materiality under securities laws does not operate to limit the Commission's rulemaking.” CFR Climate-related financial risk — “which history has shown to harm share value” CMP Standardization / comparability — “The lack of mandated disclosure with a universal corporate reporting standard means that investors have inconsistent or no information to guide their investment decision-making process” IP Investor protection / decision usefulness — “investors across the market of every size, strategy, and time horizon inform the Commission that they need particular information to price risk, allocate capital, and vote their shares, that demand is a valid basis for disclosure rulemaking.” | |||||
| ▸321 | Aug. 3, 2026 | Bryan McGannon, Managing Director, US Sustainable Investment Forum | Oppose rescission | Business trade association / advocacy org | ACCT AUTH CAPFORM CFR CMP DEMAND ENV FRAG IP GOV |
Position: Oppose rescission (unanimous) · Entity: Business trade association / advocacy org (majority) Modification posture: No modification requested — no substantive request to change the framework Keep provisions: GOV (Governance / risk management) ACCT Stewardship / accountability — “Rescinding this requirement removes a powerful, standardized mechanism
that forces corporate boards to actively manage, mitigate, and answer for long-term, highconsequence 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 — “The proposed rescission represents a significant step backward for market transparency by
denying investors access to standardized, comparable data.” DEMAND Investor demand / fund reliance — “Investors have been calling for increased disclosure and regulation around climate-related risks
for decades” ENV Environmental impact / consequences — “A study from the University of Chicago and University of Pennsylvania estimates the present value
of social costs generated by US companies' future GHG emissions at $87 trillion.” FRAG Regulatory fragmentation / multi-jurisdictional consistency — “the European Union under the Corporate Sustainability Reporting Directive
(CSRD) and individual states like California under SB 253 and SB 261, are moving forward with
mandatory climate disclosures” IP Investor protection / decision usefulness — “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.” | |||||
| ▸320 | Aug. 3, 2026 | Alana R. R. Black, Senior Litigation Counsel, New Civil Liberties Alliance; Margaret A. Little, Senior Litigation Counsel, New Civil Liberties Alliance; Caitlyn Moyna, Senior Litigation Counsel, New Civil Liberties Alliance; Markham S. Chenoweth, President and Chief Legal Officer, New Civil Liberties Alliance | Support rescission | Legal practitioner | AUTH CB INSUFF |
Position: Support rescission (unanimous) · Entity: Legal practitioner (unanimous) Modification posture: No modification requested — no substantive request to change the framework AUTH Statutory authority / major-questions (either direction) — “NCLA supports the proposed rescission. The Final Rules exceeded the agency’s statutory authority at the time they were adopted.” CB Compliance burden — “To determine whether its Scope 1 and Scope 2 emissions are material, a registrant must first establish organizational and operational boundaries, adopt a reporting protocol and measure emissions it may never use for any business purpose.” INSUFF Insufficient / incoherent legal basis (either direction) — “a rescission resting on policy alone is fragile. Policy judgments change with each Commission, and a rescission justified only by cost-benefit reasoning, for example, could be reversed by a future Commission if costs decline.” | |||||
| ▸319 | Aug. 3, 2026 | CO2 Coalition, Angela Wheeler, On behalf of William Happer, Professor of Physics, Emeritus, Princeton University / Richard Lindzen, Professor of Earth, Atmospheric, and Planetary Sciences, Emeritus, Massachusetts Institute of Technology | Support rescission | Academic researcher | CB CBA ENV IMMAT IP |
Position: Support rescission (unanimous) · Entity: Academic researcher (unanimous) Modification posture: No modification requested — no substantive request to change the framework CB Compliance burden — “the Final Rule's costs are enormous” CBA Cost-benefit assessment — “Rescinding the Final Rule "could generate annualized savings of about $4.9 billion per year over the next 10 years."” ENV Environmental impact / consequences — “"higher temperatures, sea level rise, and droughts" and "hurricanes, floods, tornadoes, and wildfires"” IMMAT Immaterial / not decision-useful — “scientifically false and misleading information that these GHGs cause high temperatures and extreme weather” IP Investor protection / decision usefulness — “the Final Rule will harm, not benefit, investors because it mandates companies to disclose scientifically false and misleading information that these GHGs cause high temperatures and extreme weather” | |||||
| ▸318 | Aug. 3, 2026 | Everett M. Woodel, Jr., Acting Chief Counsel, and John Vatian, Assistant Chief Counsel, Office of Advocacy, U.S. Small Business Administration | Support rescission | Government / elected official | AUTH CAPFORM CB CBA INSUFF IP |
Position: Support rescission (unanimous) · Entity: Government / elected official (majority) Modification posture: No modification requested — no substantive request to change the framework AUTH Statutory authority / major-questions (either direction) — “Advocacy firmly believes the SEC far exceeded its statutory authority in promulgating its
climate disclosure rulemaking.” CAPFORM Market efficiency / capital formation — “Overly burdensome and misdirected disclosure requirements can cause sweeping
negative impacts, namely by deterring companies from accessing public capital, discouraging
companies from going public, and pushing firms towards private markets or even foreign
jurisdictions.” CB Compliance burden — “Advocacy estimates the annual compliance costs per
small registrant (averaged over the first ten years) to be $615,792, when using a 7 percent
discount rate.” CBA Cost-benefit assessment — “Over ten years, this
amounts to present value cost savings of $4.3 million per small
registrant.” INSUFF Insufficient / incoherent legal basis (either direction) — “The original IRFA was inadequate. It underestimated indirect impacts on small private
companies in supply chains, particularly through Scope 3 emissions pressures” IP Investor protection / decision usefulness — “better equips investors to
make informed decisions based on financially material information tailored to each registrant.” | |||||
| ▸317 | Aug. 3, 2026 | Putnam Progressives | 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 must disclose how they are destroying our environment” ENV Environmental impact / consequences — “Corporations must disclose how they are destroying our environment that's resulting in severe climate change.” | |||||
| ▸316 | Aug. 3, 2026 | Washington State Investment Board | Oppose rescission | Investor / asset manager (institutional) | Modify / Improve or Clarify ACCT AUTH CAPFORM CB CFR CMP DEMAND FRAG IP WHIP |
Position: Oppose rescission (unanimous) · Entity: Investor / asset manager (institutional) (unanimous) Modification posture: Modify / Improve or Clarify — asks for a revised, clarified or better-designed framework ACCT Stewardship / accountability — “enables investors
to evaluate companies based on differences in governance, strategy, risk management, and financial
resilience” AUTH Statutory authority / major-questions (either direction) — “we view
the disclosures to be necessary and appropriate in the public interest and for the protection of investors.” CAPFORM Market efficiency / capital formation — “A disclosure framework that provides consistent information related to these
risks advances the Commission's core mission by supporting informed investment decisions and
efficient capital markets.” CB Compliance burden — “it
may increase compliance complexity and cost by encouraging multiple overlapping reporting regimes
rather than a consistent federal baseline.” CFR Climate-related financial risk — “Physical risks, transition risks, supply chain resilience, insurance availability, and
capital expenditures are beginning to have financial impacts across all sectors.” CMP Standardization / comparability — “Standardized disclosure reduces information asymmetry, improves comparability, and enables investors
to evaluate companies based on differences in governance, strategy, risk management, and financial
resilience” DEMAND Investor demand / fund reliance — “growing investor expectations” FRAG Regulatory fragmentation / multi-jurisdictional consistency — “many companies operate globally and remain subject
to climate disclosure requirements adopted in other jurisdictions or by individual U.S. states.” IP Investor protection / decision usefulness — “investors require information regarding how companies identify, govern, and manage
material climate-related considerations” WHIP Regulatory whiplash / reliance interests / costs already incurred — “Many issuers have already invested significant resources in developing governance structures, internal
controls, and reporting systems both in response to growing investor expectations and in anticipation of
climate-related disclosure requirements.” | |||||
| ▸315 | Aug. 3, 2026 | Dick Rome | Oppose rescission | Individual | NR |
Position: Oppose rescission (majority) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework NR No substantive rationale — “Full disclosure is imperative.” | |||||
| ▸314 | Aug. 3, 2026 | Gregory Rossi | 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 — “identify significant climate risks, account for severe-weather losses” ENV Environmental impact / consequences — “This proposal is a critical issue for environmental justice communities.” IP Investor protection / decision usefulness — “Climate disclosures can help investors and the public understand how companies identify significant climate risks, account for severe-weather losses, calculate certain emissions, and describe publicly announced climate targets.” | |||||
| ▸313 | Aug. 3, 2026 | Linda McClendon | Oppose rescission | Individual | Modify / Expand NR |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: Modify / Expand — asks for stronger or broader disclosure NR No substantive rationale — “Do not remove any policies that need to be strengthened.” | |||||
| ▸312 | Aug. 3, 2026 | John | Oppose rescission | Individual | CMP ENV IP |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework CMP Standardization / comparability — “make significant climate-related information more consistent, comparable, and accessible” ENV Environmental impact / consequences — “health destroying pollution would be made much more common and harmful” IP Investor protection / decision usefulness — “Investors could instead be required to locate information across general SEC filings, voluntary sustainability reports, state disclosure systems, and other company materials” | |||||
| ▸311 | Aug. 3, 2026 | Margaret Dukes | 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 — “To adequately report possible damages to an impacted community should be the bare minimum.” ENV Environmental impact / consequences — “the lives already affected by climate change (wildfires, droughts, rising sea levels, etc.)” | |||||
| ▸310 | Aug. 3, 2026 | Jenene G. Garey | 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 — “no change required, rules are there for a reason and should n be kept in place.” | |||||
| ▸309 | Aug. 3, 2026 | Kerry Canfield | Oppose rescission | Individual | Modify / Expand CFR CMP ENV IP |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: Modify / Expand — asks for stronger or broader disclosure CFR Climate-related financial risk — “account for severe-weather losses” CMP Standardization / comparability — “make significant climate-related information more consistent, comparable, and accessible to anyone seeking it” ENV Environmental impact / consequences — “communities would lose a critical public source of environmental data they use to keep themselves safe” IP Investor protection / decision usefulness — “Investors would be forced to comb through a lot of not-necessarily-useful data.” | |||||
| ▸308 | Aug. 3, 2026 | Zach Balian | Oppose rescission | Individual | ACCT CAPFORM CBA CMP ENV IP |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework ACCT Stewardship / accountability — “The compliance costs associated with this framework are necessary to ensure that corporations are held accountable for their contributions to the ongoing climate crisis.” CAPFORM Market efficiency / capital formation — “the interference with capital formation is necessary if that capital formation is directly contributing to harm in US communities” CBA Cost-benefit assessment — “The compliance costs associated with this framework are necessary to ensure that corporations are held accountable for their contributions to the ongoing climate crisis.” CMP Standardization / comparability — “maintain consistent, comparable, and accessible climate-related information that can be easily found and read by the general public” ENV Environmental impact / consequences — “Climate change is an ever-present, life-threatening risk, and publicly traded corporations have contributed to a disproportionate quantity of emissions.” IP Investor protection / decision usefulness — “requires publicly traded companies to provide investors with information about material climate-related risks in registration statements and annual reports” | |||||
| ▸307 | Aug. 3, 2026 | Charlie Post | 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 — “They know what their impact is and therefore so should the public.” ENV Environmental impact / consequences — “We, as citizens, are seeing corporations bulldoze the gains we have made over the last few years and this should NOT be allowed.” PP Political pressure / regulatory capture — “It seems like that is what this administration wants and it is not a very intelligent stance.” | |||||
| ▸306 | Aug. 3, 2026 | Pat Mace | Oppose rescission | Individual | Modify / Expand ENV |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: Modify / Expand — asks for stronger or broader disclosure ENV Environmental impact / consequences — “THE MOST CRITICAL ISSUE FACING THE HUMAN RACE IS CLIMATE CHANGE.” | |||||
| ▸305 | Aug. 3, 2026 | Dorothea Leicher | 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 — “it will impact the ultimate outcome of my investments in a biological scale which underlies all other methods of valuation” ENV Environmental impact / consequences — “if we destroy our biological life support systems all of our "gains" will be destroyed in due order” IP Investor protection / decision usefulness — “I have done private investments and am extremely grateful for the information, because it will impact the ultimate outcome of my investments” | |||||
| ▸304 | Aug. 3, 2026 | Gerritt and Elizabeth Baker-Smith | Oppose rescission | Individual | Modify / Expand ACCT CFR CMP ENV IP |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: Modify / Expand — asks for stronger or broader disclosure ACCT Stewardship / accountability — “Oversight of climate risks by company leadership;” CFR Climate-related financial risk — “Certain financial effects connected to severe weather, flooding, drought, wildfires, extreme temperatures, sea-level rise, carbon offsets, and renewable energy credits.” CMP Standardization / comparability — “make significant climate-related information more consistent, comparable, and accessible” ENV Environmental impact / consequences — “Communities would lose a critical public source of environmental data.” IP Investor protection / decision usefulness — “Investors could instead be required to locate information across general SEC filings, voluntary sustainability reports, state disclosure systems, and other company materials.” | |||||
| ▸303 | Aug. 3, 2026 | Jo Ann Sallach | 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 — “Eliminating this would further endanger our planet as climate changes must be monitored and scientifically studied.” | |||||
| ▸302 | Aug. 3, 2026 | Erik Nielsen | Oppose rescission | Individual | Modify / Expand ENV |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: Modify / Expand — asks for stronger or broader disclosure ENV Environmental impact / consequences — “Climate change is real and it affects every person and every financial entity.” | |||||
| ▸301 | Aug. 3, 2026 | Lora Schwartzberg | Oppose rescission | Individual | Modify / Expand NR |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: Modify / Expand — asks for stronger or broader disclosure NR No substantive rationale | |||||
| ▸300 | Aug. 3, 2026 | Cassidy Zangwill | 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 — “Protect access to climate impact reports!!” IP Investor protection / decision usefulness — “disclose their environmental impact to their investors and the public” | |||||
| ▸299 | Aug. 3, 2026 | Sean Flynn | 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 — “the global cost of climate change per year is expected to rival the US gdp by 2050” IP Investor protection / decision usefulness — “Climate related disclosure rules protect investors from investing in projects or companies that may entail substantial liability risks” | |||||
| ▸298 | Aug. 3, 2026 | John Becker, Finance Manager | 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 — “the environmental information disclosures are helpful for investors and may not be explicitly spelled out for investors unless explicitly required” | |||||
| ▸297 | Aug. 3, 2026 | Robert Zeller | 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 — “Polluting the planet is done by greed.” IP Investor protection / decision usefulness — “Removing the climate disclosures just makes the decision harder by creating the need for more research.” | |||||
| ▸296 | Aug. 3, 2026 | Nansi Weil | Oppose rescission | Individual | Modify / Expand ENV PP |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: Modify / Expand — asks for stronger or broader disclosure ENV Environmental impact / consequences — “Fires of unprecedented ferocity wreck the air we need to breathe” PP Political pressure / regulatory capture — “It's imperative that lobbying or any input from legacy (backward) energy source lobbies is disregarded.” | |||||
| ▸295 | Aug. 3, 2026 | Dr. Joseph Martire | Oppose rescission | Individual | Modify / Improve or Clarify ENV |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: Modify / Improve or Clarify — asks for a revised, clarified or better-designed framework ENV Environmental impact / consequences — “increased wildfires, droughts, hurricanes, flooding, and seacoast erosion” | |||||
| ▸294 | Aug. 3, 2026 | Kenneth Gore | No position | Individual | ENV |
Position: No position (unanimous) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework ENV Environmental impact / consequences — “Climate Change is real - everyone must make some sacrifices to save this planet we take for granted!” | |||||
| ▸293 | Aug. 3, 2026 | Sandra Cobb | 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 — “account for severe-weather losses” ENV Environmental impact / consequences — “critical issue for environmental justice communities” IP Investor protection / decision usefulness — “Climate disclosures can help investors and the public understand how companies identify significant climate risks” | |||||
| ▸292 | Aug. 3, 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 — “Americans want crystal clear water, air, animals, fish, insects trees, plants, etc.” | |||||
| ▸291 | Aug. 3, 2026 | Frederick Hecker | 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 — “it is essential we know and understand corporate actions that may affect climate change” ENV Environmental impact / consequences — “In a time characterized by violent and erratic climate change, much of which can be attributed to human activity” | |||||
| ▸290 | Aug. 3, 2026 | Kristina Younger | Oppose rescission | Individual | Modify / Expand CFR CMP ENV FRAG IP |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: Modify / Expand — asks for stronger or broader disclosure CFR Climate-related financial risk — “account for severe-weather losses” CMP Standardization / comparability — “make significant climate-related information more consistent, comparable, and accessible” ENV Environmental impact / consequences — “Communities would lose a critical public source of environmental data.” FRAG Regulatory fragmentation / multi-jurisdictional consistency — “Investors could instead be required to locate information across general SEC filings, voluntary sustainability reports, state disclosure systems, and other company materials.” IP Investor protection / decision usefulness — “Climate disclosures can help investors and the public understand how companies identify significant climate risks” | |||||
| ▸289 | Aug. 3, 2026 | Brian Gingras | 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 — “identify significant climate risks, account for severe-weather losses” ENV Environmental impact / consequences — “This proposal is a critical issue for environmental justice communities.” IP Investor protection / decision usefulness — “Climate disclosures can help investors and the public understand how companies identify significant climate risks” | |||||
| ▸288 | Aug. 3, 2026 | Coral Shaffer | 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 — “information about the effects of climate change resulting from companies operating in our country” | |||||
| ▸287 | Aug. 3, 2026 | Julie Missimore, Head of Public Affairs - Americas, ACCA - Association of Chartered Certified Accountants | Oppose rescission | Accountant / Auditor | ACCT CAPFORM CB CFR CMP FRAG IP |
Position: Oppose rescission (unanimous) · Entity: Accountant / Auditor (unanimous) Modification posture: No modification requested — no substantive request to change the framework ACCT Stewardship / accountability — “Sustainability information can help boards understand risks and
opportunities, connecting those considerations to strategy, governance, and long-term
enterprise value.” CAPFORM Market efficiency / capital formation — “At a macro level, it also
supports mobilising private capital toward productive, innovative, and sustainable sectors.” CB Compliance burden — “Without alignment to a global baseline, entities risk facing fragmented
disclosure requirements, increased administrative burdens, and reduced comparability.” CFR Climate-related financial risk — “physical and transition risks that could impact a company's cash flow, profitability, asset values,
and financing costs” CMP Standardization / comparability — “we believe that a standardized,
global framework still provides companies the opportunity to determine what is material, while
also providing comparable, decision-useful information to investors” FRAG Regulatory fragmentation / multi-jurisdictional consistency — “around 40 jurisdictions had either adopted ISSB
standards, incorporated them in some way, or were in the process of finalising steps towards
their introduction” IP Investor protection / decision usefulness — “consistent, comparable and
decision-useful climate-related disclosures can help investors better assess risk, value
securities and allocate capital” | |||||
| ▸286 | Aug. 3, 2026 | Olivia Koppell | 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 — “it is industry, corporations, that need to do whatever is required to save our planet, our lives.” ENV Environmental impact / consequences — “the consequences of changing weather patterns” IP Investor protection / decision usefulness — “People need to know what the companies they invest in are doing about climate issues.” | |||||
| ▸285 | Aug. 3, 2026 | Lynda L. Cook | Oppose rescission | Individual | Modify / Expand AUTH ENV |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: Modify / Expand — asks for stronger or broader disclosure AUTH Statutory authority / major-questions (either direction) — “I don't believe that the current rules exceed their legal authority.” ENV Environmental impact / consequences — “climate change is a real thing” | |||||
| ▸284 | Aug. 3, 2026 | Louise Doozan | No position | Individual | ENV |
Position: No position (unanimous) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework ENV Environmental impact / consequences — “much cleaner air than my grandchildren are having to breathe” | |||||
| ▸283 | Aug. 3, 2026 | Nicki Elliott | 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 — “fires all over the country and floods ruining lives in Middle America” | |||||
| ▸282 | Aug. 3, 2026 | Teresa Bihl | 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 — “affecting our planet in ways that cannot be reversed” | |||||
| ▸279 | Aug. 3, 2026 | Stefan Padfield, Principal, Free Enterprise Initiative and Esther Bouquet, Senior Associate, Free Enterprise Initiative, The Heritage Foundation | Support rescission | Business trade association / advocacy org | AUTH CAPFORM CB CBA CFR CMP DEMAND FRAG IMMAT PP REDUN |
Position: Support rescission (unanimous) · Entity: Business trade association / advocacy org (unanimous) Modification posture: No modification requested — no substantive request to change the framework AUTH Statutory authority / major-questions (either direction) — “best handled by Congress, the
states, and market participants rather than by expanding the federal securities laws beyond their
traditional focus on materiality” CAPFORM Market efficiency / capital formation — “Those costs could discourage companies from entering or remaining in the public markets” CB Compliance burden — “Companies may need new data
systems, outside consultants, emissions calculations, internal controls, and third-party assurance
to compile and verify Scope 1 and Scope 2 information.” CBA Cost-benefit assessment — “the Final Rules would impose substantial costs
on public companies and their shareholders without sufficient benefits.” CFR Climate-related financial risk — “property insurance presents its primary
climate-related risk” CMP Standardization / comparability — “Standardized
disclosure may therefore reward differences in corporate structure rather than meaningful
differences in climate performance, making it harder for investors to compare similar companies.” DEMAND Investor demand / fund reliance — “The 2024 adopting release repeatedly characterized investor demand for additional climate
disclosures as a principal justification for mandatory standardized disclosure” FRAG Regulatory fragmentation / multi-jurisdictional consistency — “foreign sustainability regimes like the EU’s net-zero goals
laid out in the Paris Climate Agreement” IMMAT Immaterial / not decision-useful — “Asserted demand for information, however, is not equivalent to materiality” PP Political pressure / regulatory capture — “politically driven
climate disclosure requirements imposed by the Final Rules” REDUN Redundant — existing rules, materiality regime, or voluntary reporting already suffice — “Existing
requirements already call for disclosure of material climate-related risks” | |||||
| ▸278 | Aug. 3, 2026 | Tim Kyne | Oppose rescission | Individual | Modify / Expand CFR ENV IP PP |
Position: Oppose rescission (unanimous) · Entity: Individual (majority) Modification posture: Modify / Expand — asks for stronger or broader disclosure CFR Climate-related financial risk — “account for severe-weather losses” ENV Environmental impact / consequences — “This proposal is a critical issue for environmental justice communities.” IP Investor protection / decision usefulness — “Climate disclosures help investors and the public understand how companies identify significant climate risks” PP Political pressure / regulatory capture — “not be influenced by the executive branch or ideology” | |||||
| ▸277 | Aug. 3, 2026 | Donald Gallion | 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 will affect our natural environment as well as the value of businesses” ENV Environmental impact / consequences — “Climate change will affect our natural environment as well as the value of businesses” IP Investor protection / decision usefulness — “it is essential that these rules be retained so that investors may make a decision that is informed on the issue of climate change” | |||||
| ▸276 | Aug. 3, 2026 | Tim Kyne | Oppose rescission | Individual | Modify / Expand CFR ENV IP PP |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: Modify / Expand — asks for stronger or broader disclosure CFR Climate-related financial risk — “account for severe-weather losses, calculate certain emissions” ENV Environmental impact / consequences — “Our climate and enviornment is rapidly worsening - we need all hands on deck...” IP Investor protection / decision usefulness — “Climate disclosures help investors and the public understand how companies identify significant climate risks, account for severe-weather losses, calculate certain emissions, and describe publicly announced climate targets.” PP Political pressure / regulatory capture — “not be influenced by the executive branch or ideology” | |||||
| ▸275 | Aug. 3, 2026 | Amy M. O'Brien, Executive Vice President, Global Head of Responsible Investing and Yves P. Denizé, Senior Managing Director, Division General Counsel, Teachers Insurance and Annuity Association of America | Mixed | Investor / asset manager (institutional) | Modify / Improve or Clarify CAPFORM CB CBA CFR CMP DEMAND FRAG IP |
Position: Mixed (unanimous) · Entity: Investor / asset manager (institutional) (unanimous) Modification posture: Modify / Improve or Clarify — asks for a revised, clarified or better-designed framework CAPFORM Market efficiency / capital formation — “Over time, this disparity could become a source of market inefficiency,
threatening the fair, orderly, and efficient markets the Commission is charged with protecting.” CB Compliance burden — “harmonize with international frameworks, including TCFD
and ISSB, to reduce duplication and compliance burdens for multinational companies.” CBA Cost-benefit assessment — “The Proposal's economic analysis focuses primarily on compliance costs to registrants, but we
are concerned the Commission has given insufficient weight to the burden rescission would
impose on investors who need reliable climate risk data for informed decision-making.” CFR Climate-related financial risk — “For example, physical climate
risks such as sea-level rise, increased flooding, and more frequent or severe storms can
materially affect the value of real estate investments through mechanisms like rising insurance
costs, declining property valuations, and diminished marketability.” CMP Standardization / comparability — “we express our strong belief that a federal disclosure
framework would meaningfully benefit investors by providing the consistent, quantifiable climate
data needed for fully informed investment decisions.” DEMAND Investor demand / fund reliance — “many public
companies already disclose climate-related information in response to investor demand, stock
exchange listing expectations, or existing state and international requirements.” FRAG Regulatory fragmentation / multi-jurisdictional consistency — “Public companies could soon face a mosaic of state-specific requirements for climate risk
disclosure that differ in scope, methodology, coverage thresholds, and timing.” IP Investor protection / decision usefulness — “maintaining access to high-quality, comparable, and reliable climate risk
data is essential to sound investment decision-making, responsible stewardship of our clients'
assets, and the proper functioning of capital markets.” | |||||
| ▸274 | Aug. 3, 2026 | Alvin Goldman | Oppose rescission | Individual | ACCT CFR ENV IP |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework ACCT Stewardship / accountability — “differentiate between reckless and callous management of companies and management that is ethical and has the foresight to reduce and protect against the dangers of climate warming” CFR Climate-related financial risk — “Nor do I want my investments to be destabilized and undercut by inept managers who sacrifice the durability of assets and ignore exposure to increased risks resulting from pollutants they keep generating that increase losses from massive fires and floods, diminished fisheries, vanishing enriched soil and pure waters, and liability for catastrophic damages caused to others.” ENV Environmental impact / consequences — “the reality and serious health and economic dangers of climate change” IP Investor protection / decision usefulness — “appalled by the prospect that the SEC may eliminate or reduce disclosure requirements that allow me and my advisors to differentiate between reckless and callous management of companies and management that is ethical” | |||||
| ▸273 | Aug. 3, 2026 | David Hamel | 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.” | |||||
| ▸272 | Aug. 3, 2026 | William Goliff | Oppose rescission | Individual | Modify / Improve or Clarify ENV IP |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: Modify / Improve or Clarify — asks for a revised, clarified or better-designed framework ENV Environmental impact / consequences — “Removing environmental standards is bad for the country.” IP Investor protection / decision usefulness — “Disclosures help investors make good decisions.” | |||||
| ▸271 | Aug. 3, 2026 | Ms. Black | 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 affects our very existence: Humans, animals, nature, water and more.” | |||||
| ▸270 | Aug. 3, 2026 | William Catus | 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 — “Keep environmental protection in SEC rules.” | |||||
| ▸269 | Aug. 3, 2026 | Michael C. | No position | Individual | ENV |
Position: No position (unanimous) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework ENV Environmental impact / consequences — “destroying the ecosystem and life sustaining efforts” | |||||
| ▸268 | Aug. 3, 2026 | Marlena Elias | 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, so don't be stupid” | |||||
| ▸267 | Aug. 3, 2026 | Melissa Ditmore | Oppose rescission | Individual | CMP DEMAND ENV IP |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework CMP Standardization / comparability — “a national framework intended to make significant climate-related information more consistent, comparable, and accessible” DEMAND Investor demand / fund reliance — “I use this information in my investing.” ENV Environmental impact / consequences — “both communities and investors would lose a critical public source of environmental data” IP Investor protection / decision usefulness — “I use this information in my investing.” | |||||
| ▸266 | Aug. 3, 2026 | Larry S. Price, MD | 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 — “We must hold those accountable that are producing greenhouse gases.” ENV Environmental impact / consequences — “Climate change is real and it is humans activities that are driving it forward.” | |||||
| ▸265 | Aug. 3, 2026 | Thomas Kemp | Oppose rescission | Individual | ACCT CBA ENV PP |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework ACCT Stewardship / accountability — “they cannot be trusted to self-regulate or to be truthful about the impacts of their business unless they are required to disclose such information” CBA Cost-benefit assessment — “Environmental protection definitely has a positive economic rationale that needs to be incorporated into national policy and regulations.” ENV Environmental impact / consequences — “the habitability of Earth is further compromised” PP Political pressure / regulatory capture — “government leaders are routinely downplaying scientific research in order to promote immediate financial gain potential” | |||||
| ▸264 | Aug. 3, 2026 | L. Glasner | Oppose rescission | Individual | Modify / Expand CFR ENV IP |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: Modify / Expand — asks for stronger or broader disclosure CFR Climate-related financial risk — “account for severe-weather losses” ENV Environmental impact / consequences — “wildfires, loss of arable land, sea rise, loss of livable land mass” IP Investor protection / decision usefulness — “Climate disclosures can help investors and the public understand how companies identify significant climate risks” | |||||
| ▸263 | Aug. 3, 2026 | Victoria Greene Epps | No position | Individual | ENV |
Position: No position (unanimous) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework ENV Environmental impact / consequences — “For our Grandchildren's - the FUTURE of this Nation- Sakes!!!!” | |||||
| ▸262 | Aug. 3, 2026 | Karyn Graham | 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 — “account for severe-weather losses” ENV Environmental impact / consequences — “This proposal is a critical issue for environmental justice communities.” IP Investor protection / decision usefulness — “Climate disclosures can help investors and the public understand how companies identify significant climate risks, account for severe-weather losses, calculate certain emissions, and describe publicly announced climate targets.” | |||||
| ▸261 | Aug. 3, 2026 | Barbara Coleman | 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 — “Keep disclosure rules in place.” | |||||
| ▸260 | Aug. 3, 2026 | Julie Edwards | Oppose rescission | Individual | CMP ENV IP |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework CMP Standardization / comparability — “more consistent, comparable, and accessible” ENV Environmental impact / consequences — “Communities would lose a critical public source of environmental data” IP Investor protection / decision usefulness — “Investors could instead be required to locate information across general SEC filings, voluntary sustainability reports, state disclosure systems, and other company materials” | |||||
| ▸259 | Aug. 3, 2026 | Tracy Wong | Oppose rescission | Individual | Modify / Expand ACCT ENV |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: Modify / Expand — asks for stronger or broader disclosure ACCT Stewardship / accountability — “This transparency will keep them accountable and ensure they are good stewards of our shared planet.” ENV Environmental impact / consequences — “We have failed to address climate change for too long.” | |||||
| ▸258 | Aug. 3, 2026 | Robert Richard Faszczewski | 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 — “protect our environment” IP Investor protection / decision usefulness — “I feel it is particularly important that I know the environmental effects of any investment I” | |||||
| ▸257 | Aug. 3, 2026 | Pat | Oppose rescission | Individual | ACCT ENV INSUFF PP |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework ACCT Stewardship / accountability — “keeping industry accountable for spoiling our climate” ENV Environmental impact / consequences — “checks on climate damage” INSUFF Insufficient / incoherent legal basis (either direction) — “The given reasons for removing these steps are not sufficient and not aimed at the public good.” PP Political pressure / regulatory capture — “appeasing businesspeople and greedy politicians” | |||||
| ▸256 | Aug. 3, 2026 | Erika Gesue | 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 — “account for severe-weather losses” ENV Environmental impact / consequences — “calculate certain emissions” IP Investor protection / decision usefulness — “Climate disclosures can help investors and the public understand how companies identify significant climate risks” | |||||
| ▸255 | Aug. 3, 2026 | Jennifer Marie Swann | 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 — “You guys are in charge. Fix it!” ENV Environmental impact / consequences — “the hurricanes, drought, floods, earthquakes, etc., all at once) that the climate is woefully out of balance” | |||||
| ▸254 | Aug. 3, 2026 | Brooke Babineau | 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 — “account for severe-weather losses” ENV Environmental impact / consequences — “This proposal is a critical issue for environmental justice communities.” IP Investor protection / decision usefulness — “Climate disclosures can help investors and the public understand how companies identify significant climate risks, account for severe-weather losses, calculate certain emissions, and describe publicly announced climate targets.” | |||||
| ▸253 | Aug. 3, 2026 | Kevin Tucker | 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 — “material climate-related risks in registration statements and annual reports” IP Investor protection / decision usefulness — “provide investors with information about material climate-related risks” | |||||
| ▸252 | Aug. 3, 2026 | Michael R. Horner | 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 — “communities and families that literally depend upon clean air, water, and sanitation services” | |||||
| ▸251 | Aug. 3, 2026 | Nita Cunningham | 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 — “Is it not hot enough yet?” | |||||
| ▸250 | Aug. 3, 2026 | Reuben Wade | Oppose rescission | Individual | Modify / Expand ENV IP |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: Modify / Expand — asks for stronger or broader disclosure ENV Environmental impact / consequences — “This proposal is a critical issue for environmental justice communities.” IP Investor protection / decision usefulness — “Climate disclosures can help investors and the public understand how companies identify significant climate risks, account for severe-weather losses, calculate certain emissions, and describe publicly announced climate targets.” | |||||
| ▸249 | Aug. 3, 2026 | Perry Callas | 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 — “wildfires are burning out of control in Oregon and Washington” | |||||
| ▸248 | Aug. 3, 2026 | Melanie Peschel | Oppose rescission | Individual | ENV PP |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework ENV Environmental impact / consequences — “no concern for the consequences to the world and its inhabitants” PP Political pressure / regulatory capture — “looks very much like rampant corruption” | |||||
| ▸247 | Aug. 3, 2026 | Rachel Brennan | Oppose rescission | Individual | ACCT CFR ENV IP |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework ACCT Stewardship / accountability — “account for severe-weather losses, calculate certain emissions, and describe publicly announced climate targets” CFR Climate-related financial risk — “identify significant climate risks, account for severe-weather losses” ENV Environmental impact / consequences — “This proposal is a critical issue for environmental justice communities.” IP Investor protection / decision usefulness — “Climate disclosures can help investors and the public understand how companies identify significant climate risks” | |||||
| ▸246 | Aug. 3, 2026 | William R. Cavins | Oppose rescission | Individual | ACCT CAPFORM INSUFF IP |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework ACCT Stewardship / accountability — “markets remain fair, transparent, and accountable” CAPFORM Market efficiency / capital formation — “maintaining orderly, efficient markets” INSUFF Insufficient / incoherent legal basis (either direction) — “Any decision to withdraw existing or proposed safeguards should be supported by compelling evidence that doing so would improve these objectives.” IP Investor protection / decision usefulness — “prioritizing investor protection, transparency, and market integrity” | |||||
| ▸245 | Aug. 3, 2026 | Melissa Wilander | Oppose rescission | Individual | CFR ENV IP |
Position: Oppose rescission (majority) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework CFR Climate-related financial risk — “account for severe-weather losses” ENV Environmental impact / consequences — “This proposal is a critical issue for environmental justice communities.” IP Investor protection / decision usefulness — “Climate disclosures can help investors and the public understand how companies identify significant climate risks” | |||||
| ▸244 | Aug. 3, 2026 | Linda Morgan | Oppose rescission | Individual | CMP ENV IP |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework CMP Standardization / comparability — “more consistent, comparable, and accessible” ENV Environmental impact / consequences — “Communities would lose a critical public source of environmental data” IP Investor protection / decision usefulness — “Investors could instead be required to locate information across general SEC filings, voluntary sustainability reports, state disclosure systems, and other company materials” | |||||
| ▸243 | Aug. 3, 2026 | Nick Hammer | No position | Individual | ENV |
Position: No position (unanimous) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework ENV Environmental impact / consequences — “It is more important than ever to try to control the harmful emissions the must inevitably be produced by manufacturing and every day activities.” | |||||
| ▸242 | Aug. 3, 2026 | Chandra Larsen | Oppose rescission | Individual | Modify / Expand ACCT CFR CMP ENV FRAG IP GHG12 GOV TARGETS FINSTMT |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: Modify / Expand — asks for stronger or broader disclosure Keep provisions: GHG12 (Scope 1 & 2 emissions), GOV (Governance / risk management), TARGETS (Targets / transition plan), FINSTMT (Financial-statement effects (Reg S-X Art. 14)) ACCT Stewardship / accountability — “Oversight of climate risks by company leadership” CFR Climate-related financial risk — “Certain financial effects connected to severe weather, flooding, drought, wildfires, extreme temperatures, sea-level rise, carbon offsets, and renewable energy credits.” CMP Standardization / comparability — “a national framework intended to make significant climate-related information more consistent, comparable, and accessible” ENV Environmental impact / consequences — “Communities would lose a critical public source of environmental data.” FRAG Regulatory fragmentation / multi-jurisdictional consistency — “Investors could instead be required to locate information across general SEC filings, voluntary sustainability reports, state disclosure systems, and other company materials.” IP Investor protection / decision usefulness — “Investors could instead be required to locate information across general SEC filings, voluntary sustainability reports, state disclosure systems, and other company materials.” | |||||
| ▸241 | Aug. 3, 2026 | Susan J. Morris | Oppose rescission | Individual | Modify / Expand ENV |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: Modify / Expand — asks for stronger or broader disclosure ENV Environmental impact / consequences — “Climate change is effecting all we hold essential, such as food supply, heat we are having difficulty living with and is causing premature death, damaging wild fires, tornadoes etc.” | |||||
| ▸240 | Aug. 3, 2026 | Pat Gorman | No position | Individual | ENV |
Position: No position (unanimous) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework ENV Environmental impact / consequences — “air, water, soil even us getting so polluted” | |||||
| ▸239 | Aug. 3, 2026 | Mary Jo Root | Oppose rescission | Individual | ENV INSUFF |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework ENV Environmental impact / consequences — “rules protecting their health and well being” INSUFF Insufficient / incoherent legal basis (either direction) — “protected from irrational changes to rules” | |||||
| ▸238 | Aug. 3, 2026 | Kim McGillivray | 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 — “community protections provided by the current disclosure rules” | |||||
| ▸237 | Aug. 3, 2026 | Joseph Kenosky | Oppose rescission | Individual | Modify / Expand ENV |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: Modify / Expand — asks for stronger or broader disclosure ENV Environmental impact / consequences — “Communities across the country would lose access to an important source of public environmental data.” | |||||
| ▸236 | Aug. 3, 2026 | Tracy Elms | Oppose rescission | Individual | Modify / Expand ACCT CFR CMP ENV IP GHG12 GOV TARGETS FINSTMT |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: Modify / Expand — asks for stronger or broader disclosure Keep provisions: GHG12 (Scope 1 & 2 emissions), GOV (Governance / risk management), TARGETS (Targets / transition plan), FINSTMT (Financial-statement effects (Reg S-X Art. 14)) ACCT Stewardship / accountability — “Oversight of climate risks by company leadership” CFR Climate-related financial risk — “Certain financial effects connected to severe weather, flooding, drought, wildfires, extreme temperatures, sea-level rise, carbon offsets, and renewable energy credits” CMP Standardization / comparability — “more consistent, comparable, and accessible” ENV Environmental impact / consequences — “Communities would lose a critical public source of environmental data” IP Investor protection / decision usefulness — “require publicly traded companies to provide investors with information about material climate-related risks in registration statements and annual reports” | |||||
| ▸235 | Aug. 3, 2026 | Stuart Rubinow | Oppose rescission | Individual | Modify / Expand CFR CMP ENV IP |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: Modify / Expand — asks for stronger or broader disclosure CFR Climate-related financial risk — “account for severe-weather losses, calculate certain emissions, and describe publicly announced climate targets.” CMP Standardization / comparability — “a national framework intended to make significant climate-related information more consistent, comparable, and accessible” ENV Environmental impact / consequences — “Communities would lose a critical public source of environmental data.” IP Investor protection / decision usefulness — “Those rules require publicly traded companies to provide investors with information about material climate-related risks in registration statements and annual reports.” | |||||
| ▸234 | Aug. 3, 2026 | John Galloway, Principal, Head of Investor Engagement, The Vanguard Group, Inc. | Mixed | Investor / asset manager (institutional) | Modify / Improve or Clarify CAPFORM CB CFR CMP FRAG IP |
Position: Mixed (unanimous) · Entity: Investor / asset manager (institutional) (unanimous) Modification posture: Modify / Improve or Clarify — asks for a revised, clarified or better-designed framework CAPFORM Market efficiency / capital formation — “enable more accurate valuations and efficient price discovery.” CB Compliance burden — “including climate-related disclosures — that are costly, confusing and overly burdensome.” CFR Climate-related financial risk — “When a company has identified material climate-related risks, disclosure about these risks should” CMP Standardization / comparability — “there is also value in the standardized and comparable” FRAG Regulatory fragmentation / multi-jurisdictional consistency — “We have also observed that climate-related disclosure requirements can vary by jurisdiction” IP Investor protection / decision usefulness — “material information so investors can evaluate risk and make informed decisions.” | |||||
| ▸233 | Aug. 3, 2026 | Sharon Hamm | Oppose rescission | Individual | Modify / Expand ENV |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: Modify / Expand — asks for stronger or broader disclosure ENV Environmental impact / consequences — “It is imperative for our health and the future of our planet” | |||||
| ▸232 | Aug. 3, 2026 | Ralphie Beam | Oppose rescission | Individual | NR |
Position: Oppose rescission (majority) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework NR No substantive rationale — “Sec not be permanent with draw the rules” | |||||
| ▸231 | Aug. 3, 2026 | Mona Carpenter | 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 — “THIS IS VERY DANGEROUS AND POTENTIALLY HARMFUL TO ALL OF US” | |||||
| ▸230 | Aug. 3, 2026 | Pat Byrne Pash | 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 — “Let's show concern about future generations!” | |||||
| ▸229 | Aug. 3, 2026 | Susan Baltes Stewart | 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 — “account for severe-weather losses” ENV Environmental impact / consequences — “This proposal is a critical issue for environmental justice communities.” IP Investor protection / decision usefulness — “Climate disclosures can help investors and the public understand how companies identify significant climate risks” | |||||
| ▸228 | Aug. 3, 2026 | Marilyn E. Lemons | 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 — “the climate changes damaging our planet” | |||||
| ▸227 | Aug. 3, 2026 | Reynold Wiggins | 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 — “will encourage damage to the environment and damage to the population.” | |||||
| ▸226 | Aug. 3, 2026 | Richard Gibbons | Oppose rescission | Individual | Modify / Expand ENV IP |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: Modify / Expand — asks for stronger or broader disclosure ENV Environmental impact / consequences — “This proposal is a critical issue for environmental justice communities.” IP Investor protection / decision usefulness — “Climate disclosures can help investors and the public understand how companies identify significant climate risks, account for severe-weather losses, calculate certain emissions, and describe publicly announced climate targets.” | |||||
| ▸225 | Aug. 3, 2026 | Stephan Donovan | No position | Individual | ENV |
Position: No position (unanimous) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework ENV Environmental impact / consequences — “The world is on fire.” | |||||
| ▸224 | Aug. 3, 2026 | Jack Paul | 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 — “This is needed info and part of the protection to our environment.” | |||||
| ▸223 | Aug. 3, 2026 | Alexis Uraga Campos | 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 and the impacts it will have on us if we fail to mitigate it in time” | |||||
| ▸222 | Aug. 3, 2026 | Barbara Methvin | 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 — “Keep climate-related disclosure rules in place (S7-2026-19)” | |||||
| ▸221 | Aug. 3, 2026 | Adelina Zottola | Oppose rescission | Individual | Modify / Expand CMP |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: Modify / Expand — asks for stronger or broader disclosure CMP Standardization / comparability — “consistent, reliable, and accessible climate information” | |||||
| ▸220 | Aug. 3, 2026 | Lawrence E. Adler | 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 — “critical for safety and preventing climate-related disasters” | |||||
| ▸219 | Aug. 3, 2026 | Meghan E. | Oppose rescission | Individual | CMP ENV IP |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework CMP Standardization / comparability — “a national framework intended to make significant climate-related information more consistent, comparable, and accessible” ENV Environmental impact / consequences — “these regulations help ensure that all is being done to keep humanity safe from climate disasters” IP Investor protection / decision usefulness — “Investors could instead be required to locate information across general SEC filings, voluntary sustainability reports, state disclosure systems, and other company materials.” | |||||
| ▸218 | Aug. 3, 2026 | Patty Linder | Oppose rescission | Individual | Modify / Expand NR |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: Modify / Expand — asks for stronger or broader disclosure NR No substantive rationale — “These rules should be strengthened, not rescinded.” | |||||
| ▸217 | Aug. 3, 2026 | Dave Hall | 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 — “Do NOT rescind the 2024 climate-related disclosure rules!” | |||||
| ▸216 | Aug. 3, 2026 | Mike Benson | 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 — “essential if we are to move forward and avoid extinction” IP Investor protection / decision usefulness — “Hiding crucial information from investors and the public” | |||||
| ▸215 | Aug. 3, 2026 | Simone Pisias | 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 — “The world is on fire, literally” | |||||
| ▸214 | Aug. 3, 2026 | L. Dill | Oppose rescission | Individual | CMP ENV IP |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework CMP Standardization / comparability — “more consistent, comparable, and accessible” ENV Environmental impact / consequences — “This proposal is a critical issue for environmental justice communities.” IP Investor protection / decision usefulness — “provide investors with information about material climate-related risks in registration statements and annual reports” | |||||
| ▸213 | Aug. 3, 2026 | Michael Faulkender, Co-Chair, Center for American Prosperity, America First Policy Institute | Support rescission | Business trade association / advocacy org | ACCT AUTH CAPFORM CB CBA CFR CMP DEMAND ENV FRAG IMMAT REDUN |
Position: Support rescission (unanimous) · Entity: Business trade association / advocacy org (unanimous) Modification posture: No modification requested — no substantive request to change the framework ACCT Stewardship / accountability — “Board-level oversight of climate risk must be disclosed regardless of the materiality of the risk.” AUTH Statutory authority / major-questions (either direction) — “Congress has repeatedly considered and declined to assign to the Commission” CAPFORM Market efficiency / capital formation — “IPO decisions more strongly than they induce public firms to go” CB Compliance burden — “fixed compliance costs falling disproportionately on smaller issuers.” CBA Cost-benefit assessment — “recurring annual savings reaching $5.6 billion, a present value of $42.3 billion over ten” CFR Climate-related financial risk — “produced estimates of transition-risk impact that differed by more” CMP Standardization / comparability — “Pairwise correlations among major ESG ratings run from just 0.38 to 0.71” DEMAND Investor demand / fund reliance — “The peer-reviewed literature finds limited evidence of investor demand for firm-level” ENV Environmental impact / consequences — “improved carbon intensity but no reduction in absolute emissions” FRAG Regulatory fragmentation / multi-jurisdictional consistency — “cut total ESRS datapoints by more than 70%” IMMAT Immaterial / not decision-useful — “uncertain, model-dependent, and only superficially comparable.” REDUN Redundant — existing rules, materiality regime, or voluntary reporting already suffice — “Rescission would not create a disclosure vacuum.” | |||||
| ▸212 | Aug. 3, 2026 | Janet Peargin | Oppose rescission | Issuer / Corporate — former | ACCT CFR ENV IP |
Position: Oppose rescission (unanimous) · Entity: Issuer / Corporate — former (unanimous) Modification posture: No modification requested — no substantive request to change the framework ACCT Stewardship / accountability — “We need industry oversight in order to improve and innovate.” CFR Climate-related financial risk — “disclose their climate risks in financial filings” ENV Environmental impact / consequences — “led to significant and cost-effective reductions in methane, etc. emissions” IP Investor protection / decision usefulness — “leaves investors and the public in the dark when it comes to climate risk” | |||||
| ▸211 | Aug. 3, 2026 | Institute for Policy Integrity at NYU School of Law | Oppose rescission | Legal practitioner | Fallback / Compromise ACCT AUTH CAPFORM CBA CFR CMP DEMAND FRAG INSUFF IP |
Position: Oppose rescission (unanimous) · Entity: Legal practitioner (majority) Modification posture: Fallback / Compromise — primary position is clear; a second-best alternative is offered if it is rejected ACCT Stewardship / accountability — “oversight
systems at the board level can provide an important signal about how directors of the registrants
recognize and address relevant climate-related risks” AUTH Statutory authority / major-questions (either direction) — “The Major Questions Doctrine Does Not Justify Rescinding the 2024 Rules” CAPFORM Market efficiency / capital formation — “the disclosure otherwise protects
investors and promotes efficiency, competition, and capital formation” CBA Cost-benefit assessment — “The SEC’s economic
analysis was therefore arbitrary and capricious” CFR Climate-related financial risk — “physical risks could result in asset impairments and business interruptions” CMP Standardization / comparability — “The 2024 Rules merely add more detail, improving the comparability and decision-usefulness of
the information” DEMAND Investor demand / fund reliance — “Investors have signaled a
particular interest in understanding how companies are managing climate-related risks in order to
understand their own risk exposure” FRAG Regulatory fragmentation / multi-jurisdictional consistency — “the proliferation of
mandatory climate-related financial disclosure regimes” INSUFF Insufficient / incoherent legal basis (either direction) — “The SEC Acted Arbitrarily in Rescinding the 2024 Rules in Their Entirety” IP Investor protection / decision usefulness — “provide investors with information that is important to their
investment and voting decisions” | |||||
| ▸210 | Aug. 3, 2026 | Benjamin L. Schiffrin, Director of Securities Policy, Better Markets, Inc. | Oppose rescission | Environmental / ESG advocacy org | ACCT AUTH CAPFORM CFR CMP DEMAND FRAG INSUFF IP PP |
Position: Oppose rescission (unanimous) · Entity: Environmental / ESG advocacy org (unanimous) Modification posture: No modification requested — no substantive request to change the framework ACCT Stewardship / accountability — “facilitate an evaluation of management’s stewardship over corporate assets” AUTH Statutory authority / major-questions (either direction) — “authorize the Commission to ensure that public company disclosures provide investors with
information important to making informed investment and voting decisions” CAPFORM Market efficiency / capital formation — “important for price discovery
and long-term shareholder returns” CFR Climate-related financial risk — “climate-related risks can affect a
company’s business and its financial performance and position in a variety of ways” CMP Standardization / comparability — “standardize and enhance the information available to investors about such matters” DEMAND Investor demand / fund reliance — “the overwhelming majority” wanted climate risk disclosures” FRAG Regulatory fragmentation / multi-jurisdictional consistency — “as states and other global
governments move forward with their own climate risk disclosure guidelines” INSUFF Insufficient / incoherent legal basis (either direction) — “the quotation refers not to the SEC but to the
Occupational Safety and Health Administration in a case about vaccine mandates” IP Investor protection / decision usefulness — “elicit information that investors have indicated is important to their
investment and voting decisions.” PP Political pressure / regulatory capture — “it is this Commission that believes, for political reasons, that only
climate-related risks should not be disclosed to investors” | |||||
| ▸209 | Aug. 3, 2026 | David Blood, Senior Partner, Generation Investment Management LLP | Oppose rescission | Investor / asset manager (institutional) | ACCT 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 ACCT Stewardship / accountability — “to inform stewardship activities, including proxy voting” CFR Climate-related financial risk — “climate change is a material issue for the companies” CMP Standardization / comparability — “consistent, reliable and comparable reporting by the companies we assess and own” DEMAND Investor demand / fund reliance — “from a broad range of mainstream investors, who sought it because it bears” FRAG Regulatory fragmentation / multi-jurisdictional consistency — “would reduce the comparability of US companies with their international peers” INSUFF Insufficient / incoherent legal basis (either direction) — “in our assessment the Rescission Proposal does not” IP Investor protection / decision usefulness — “Our clients have mandated us to integrate sustainability factors, including climate-related risks and opportunities” | |||||
| ▸208 | Aug. 3, 2026 | Sierra Club | Oppose rescission | Environmental / ESG advocacy org | ACCT AUTH CAPFORM CFR CMP DEMAND ENV FRAG IP |
Position: Oppose rescission (unanimous) · Entity: Environmental / ESG advocacy org (unanimous) Modification posture: No modification requested — no substantive request to change the framework ACCT Stewardship / accountability — “required to describe management’s role and the board of directors’ oversight of climate risks, including how” AUTH Statutory authority / major-questions (either direction) — “The Commission has clear statutory authority to require standardized disclosures needed to
protect investors and promote fair and efficient markets.” CAPFORM Market efficiency / capital formation — “making markets function efficiently” CFR Climate-related financial risk — “climate risks are already affecting asset valuations, the cost of capital, and” CMP Standardization / comparability — “the reliable, comparable, and decision-useful information” DEMAND Investor demand / fund reliance — “investors have, for years, called for improved climate-related
disclosures.” ENV Environmental impact / consequences — “Lower-income communities and communities of color are more vulnerable to the adverse impacts of
climate change.” FRAG Regulatory fragmentation / multi-jurisdictional consistency — “many governments are working toward mandatory disclosure frameworks, including those in the United Kingdom, the European Union, and New Zealand” IP Investor protection / decision usefulness — “enabling investors to effectively assess and manage risk” | |||||
| ▸207 | Aug. 3, 2026 | Aldo Bonati, Stewardship and ESG Networks Manager, Etica Sgr | Oppose rescission | Investor / asset manager (institutional) | ACCT AUTH CAPFORM 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 — “climate governance, and supply-chain emissions management.” AUTH Statutory authority / major-questions (either direction) — “unprecedented and illogical argument that it somehow lacks the authority to do what Congress” CAPFORM Market efficiency / capital formation — “framework that promotes efficient capital markets, supports” CFR Climate-related financial risk — “Climate change represents a financially material risk for many companies and sovereign issuers in” CMP Standardization / comparability — “and reliable climate-related disclosures are essential for informed investment decision-making” DEMAND Investor demand / fund reliance — “institutional investors emphasized that the Rules were necessary to better understand which” FRAG Regulatory fragmentation / multi-jurisdictional consistency — “mandatory disclosures for companies doing business in California and the E.U.” IP Investor protection / decision usefulness — “Access to reliable climate-related disclosures is essential for effective investment analysis and” | |||||
| ▸206 | Aug. 3, 2026 | Luan Jenifer, CEO & President, Miller/Howard Investments, Inc. | Oppose rescission | Investor / asset manager (institutional) | ACCT CAPFORM CBA CFR CMP DEMAND 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 — “how to vote on board elections and shareholder
proposals” CAPFORM Market efficiency / capital formation — “Mandatory climate-related disclosure requirements are a necessary precursor to informed and efficient markets” CBA Cost-benefit assessment — “rescission of the Rules would harm investors and would impose additional costs to obtain climate risk
information” CFR Climate-related financial risk — “identifying material risks related to climate events has never been
more urgent” CMP Standardization / comparability — “compare one company’s profile and performance on such to that of its peers” DEMAND Investor demand / fund reliance — “the record demonstrates substantial investor demand for
climate-related risk disclosures” IP Investor protection / decision usefulness — “would enrich, inform, and support investment
decision-making, portfolio construction, and proxy voting efforts” | |||||
| ▸205 | Aug. 3, 2026 | Melissa Simpson, President, Western Energy Alliance | Support rescission | Business trade association / advocacy org | Fallback / Compromise 1A AUTH CAPFORM CB CBA CFR CMP ENV FRAG IMMAT INSUFF PP REDUN |
Position: Support rescission (unanimous) · Entity: Business trade association / advocacy org (unanimous) Modification posture: Fallback / Compromise — primary position is clear; a second-best alternative is offered if it is rejected 1A Compelled speech / First Amendment (either direction) — “the Final Rules compelled speech with respect to climate change.” AUTH Statutory authority / major-questions (either direction) — “rules adopted by the Commission in 2024 (Final Rules) were
breathtaking in their assumption of authority far beyond the Security and Exchange
Commission’s (SEC) governing statutes” CAPFORM Market efficiency / capital formation — “the greater public interest in efficient markets,
competition, capital formation, and the myriad benefits that flow from a robust free-market
economy thus supported.” CB Compliance burden — “As oil and natural gas companies would bear the brunt of the
$4.9 billion in cost of the Final Rules, our members very much appreciate the Rescission Rule.” CBA Cost-benefit assessment — “SEC only contemplates the compliance costs and not the societal
costs that result from making the supply of energy and other goods more expensive and limited.” CFR Climate-related financial risk — “The 6% climate change policy risk represents a higher loss by 2050 than the 3% economic impact that
IPCC projects out to the end of the century” CMP Standardization / comparability — “this rule
requires information standardized in name only, especially with regard to Scope 3 emissions.” ENV Environmental impact / consequences — “Oil and natural gas also provide a net benefit to the environment.” FRAG Regulatory fragmentation / multi-jurisdictional consistency — “The EU’s experience highlights the flaws in mandating highly prescriptive disclosure regimes
similar to the Final Rules.” IMMAT Immaterial / not decision-useful — “Climate-related information is often not material, especially when viewed in the context of an
appropriate time horizon” INSUFF Insufficient / incoherent legal basis (either direction) — “The rule is
arbitrary and capricious without substantial evidence demonstrating that climate-related
information actually improves investment returns for investors.” PP Political pressure / regulatory capture — “financial regulations designed to
limit American producers, the same agenda advanced by a Russian front group.” REDUN Redundant — existing rules, materiality regime, or voluntary reporting already suffice — “must already
report their emissions, in the SEC rule termed “Scope 1”, to EPA under the GHG Reporting
Program (GHGRP)” | |||||
| ▸204 | Aug. 3, 2026 | NZAOA | Oppose rescission | Investor / asset manager (institutional) | Modify / Improve or Clarify ACCT CAPFORM CB CFR CMP FRAG IP |
Position: Oppose rescission (majority) · Entity: Investor / asset manager (institutional) (unanimous) Modification posture: Modify / Improve or Clarify — asks for a revised, clarified or better-designed framework ACCT Stewardship / accountability — “Asset owners need reliable information on emissions,
targets, transition plans, capital allocation, governance, stewardship and
implementation progress to evaluate issuers, compare investments, oversee asset
managers and engage effectively.” CAPFORM Market efficiency / capital formation — “Well-designed disclosure frameworks help markets price relevant
information more effectively, reduce information asymmetries, facilitate informed
capital allocation decisions, and support more informed, accountable and efficient
investment decision-making.” CB Compliance burden — “We recognize that disclosure
requirements impose costs on issuers and should be proportionate, operationally
practical and responsive to investor needs.” CFR Climate-related financial risk — “can still affect expected returns, asset values, liabilities,
resilience, cost of capital or the delivery of long-term investment objectives” CMP Standardization / comparability — “enable
the assessment of financially material exposures across companies, sectors, asset
classes and jurisdictions on a more consistent basis” FRAG Regulatory fragmentation / multi-jurisdictional consistency — “we support efforts to improve the quality, consistency and
interoperability of climate-related reporting requirements, where they are aligned with
investor needs and avoid unnecessary duplication” IP Investor protection / decision usefulness — “climate-related information is relevant where it helps assess risks and opportunities
that may affect portfolio value, expected returns, cashflows, liabilities, investment
strategy, stewardship priorities and the ability to meet investment objectives over the
relevant time horizon” | |||||
| ▸203 | Aug. 3, 2026 | Chicory Wealth | Oppose rescission | Investor / asset manager (institutional) | ACCT CAPFORM CFR CMP DEMAND FRAG IP GOV |
Position: Oppose rescission (unanimous) · Entity: Investor / asset manager (institutional) (unanimous) Modification posture: No modification requested — no substantive request to change the framework Keep provisions: GOV (Governance / risk management) ACCT Stewardship / accountability — “the governance, risk management, and
climate-related financial disclosure requirements” CAPFORM Market efficiency / capital formation — “Less efficient capital allocation” CFR Climate-related financial risk — “Physical risks to facilities and infrastructure” CMP Standardization / comparability — “Standardized disclosures level the playing field” DEMAND Investor demand / fund reliance — “97% of institutional investor comment letters supported requiring” FRAG Regulatory fragmentation / multi-jurisdictional consistency — “requirements in California, the European Union, and other” IP Investor protection / decision usefulness — “we have a fiduciary responsibility to make investment decisions using information” | |||||
| ▸202 | Aug. 3, 2026 | Campbell Pryde, President and CEO, XBRL US | Oppose rescission | Business trade association / advocacy org | CAPFORM CB CFR CMP DEMAND IP |
Position: Oppose rescission (unanimous) · Entity: Business trade association / advocacy org (unanimous) Modification posture: No modification requested — no substantive request to change the framework CAPFORM Market efficiency / capital formation — “result is mispricing and a misallocation of capital, which harms investors” CB Compliance burden — “enabling economies of scale that keep
regulatory reporting, data collection, and analysis costs low.” CFR Climate-related financial risk — “current disclosure policies do
not require companies to disclose the information that investors need to price climate risk, and” CMP Standardization / comparability — “prepared and made available in structured,
standardized format, it can be readily commingled, enabling comparison and analysis” DEMAND Investor demand / fund reliance — “75% of senior-level respondents said it is important or very important.” IP Investor protection / decision usefulness — “companies should only be required to disclose what
information is of material interest to investors.” | |||||
| ▸201 | Aug. 3, 2026 | Richard Morrison, Senior Fellow, Competitive Enterprise Institute | Support rescission | Business trade association / advocacy org | 1A AUTH CAPFORM CB CBA IMMAT INSUFF PP REDUN |
Position: Support rescission (unanimous) · Entity: Business trade association / advocacy org (unanimous) Modification posture: No modification requested — no substantive request to change the framework 1A Compelled speech / First Amendment (either direction) — “the disclosures that the climate disclosure rule currently requires
constitute compelled speech on the part of public companies” AUTH Statutory authority / major-questions (either direction) — “its authority to require public
companies to make disclosures of financially material information does not extend to
environmental and social topics like climate change” CAPFORM Market efficiency / capital formation — “The Final Rules are at odds with the Commission’s policy objectives of facilitating
capital formation and promoting public company status” CB Compliance burden — “the SEC has the authority to impose fines and initiate legal actions” CBA Cost-benefit assessment — “The Final Rules do impose substantial costs that are not justified by the
informational benefits they may provide to some investors” IMMAT Immaterial / not decision-useful — “The Final Rules are unnecessary and inconsistent with a registrant-specific,
materiality-based approach to disclosure” INSUFF Insufficient / incoherent legal basis (either direction) — “The agency has routinely cited industry and professional sources with
clear direct interests in the outcome of the rule as authorities on why it should be passed” PP Political pressure / regulatory capture — “corporations that sell climate-themed financial, consulting, and auditing products are
in favor of more stringent climate finance regulations that guarantee demand for their
services” REDUN Redundant — existing rules, materiality regime, or voluntary reporting already suffice — “leave the supply of detailed information
on climate-themed corporate operations to those data providers best situated to provide it
in a competitive marketplace” | |||||
| ▸200 | Aug. 3, 2026 | Nancy Vann | Oppose rescission | Individual | CFR IP |
Position: Oppose rescission (majority) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework CFR Climate-related financial risk — “will affect their future business and earnings” IP Investor protection / decision usefulness — “important considerations when investors are choosing between different options.” | |||||
| ▸199 | Aug. 3, 2026 | Ryan Smith, Responsible Investment Lead, Aegon UK | Oppose rescission | Investor / asset manager (institutional) | CAPFORM 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 CAPFORM Market efficiency / capital formation — “support the long-term
resilience of financial markets” CFR Climate-related financial risk — “Climate change presents financially material risks through physical impacts, transition risks” CMP Standardization / comparability — “consistent, comparable, and decision-useful
information” DEMAND Investor demand / fund reliance — “institutional investors require to fulfil their investment
responsibilities” FRAG Regulatory fragmentation / multi-jurisdictional consistency — “IFRS S1 and S2 are currently either in the
process of being adopted or have already been adopted in more than 40 jurisdictions” IP Investor protection / decision usefulness — “we rely on consistent and comparable
disclosure of financially material information” | |||||
| ▸198 | Aug. 3, 2026 | Matthew D. Brusch, CAE, President and CEO, National Investor Relations Institute | Support rescission | Business trade association / advocacy org | Fallback / Compromise CB CBA IMMAT IP REDUN |
Position: Support rescission (unanimous) · Entity: Business trade association / advocacy org (unanimous) Modification posture: Fallback / Compromise — primary position is clear; a second-best alternative is offered if it is rejected CB Compliance burden — “a myriad of highly prescriptive regulations that mandate granular
disclosures focused exclusively on climate-related matters” CBA Cost-benefit assessment — “The cost estimates for the Final Rules were in the billions of dollars each year, without
justifiable information benefits to investors and the capital markets.” IMMAT Immaterial / not decision-useful — “the mandates in the Final Rules, if applied to all public companies, would only result
in the disclosure of an overabundance of non-material information of limited usefulness to
the substantial majority of investors” IP Investor protection / decision usefulness — “Ensuring that
any new disclosure standards are rooted in the materiality standard is critical to preserving
the ability of investors to identify and act on decision-useful information.” REDUN Redundant — existing rules, materiality regime, or voluntary reporting already suffice — “Companies that currently emit significant amounts of greenhouse gases already are
disclosing material climate-related information to investors and regulators.” | |||||
| ▸197 | Aug. 3, 2026 | Yafit Cohn, Chief Sustainability Officer and Group General Counsel, The Travelers Companies, Inc. | Support rescission | Issuer / Corporate — current | CAPFORM CB CBA CFR IMMAT IP REDUN |
Position: Support rescission (unanimous) · Entity: Issuer / Corporate — current (unanimous) Modification posture: No modification requested — no substantive request to change the framework CAPFORM Market efficiency / capital formation — “capital formation and efficient” CB Compliance burden — “would impose substantial burdens on registrants” CBA Cost-benefit assessment — “would require extensive resources to generate information” CFR Climate-related financial risk — “material to a registrant’s business, financial condition or results of operations” IMMAT Immaterial / not decision-useful — “may have limited relevance to investment decisions.” IP Investor protection / decision usefulness — “information that a reasonable investor would consider” REDUN Redundant — existing rules, materiality regime, or voluntary reporting already suffice — “under the existing federal securities laws and Commission regulations” | |||||
| ▸196 | Aug. 3, 2026 | Angie Burckhalter, Sr. V.P. of Regulatory and Environmental Affairs, The Petroleum Alliance of Oklahoma | Support rescission | Business trade association / advocacy org | AUTH CAPFORM CB CBA IMMAT INSUFF |
Position: Support rescission (unanimous) · Entity: Business trade association / advocacy org (unanimous) Modification posture: No modification requested — no substantive request to change the framework AUTH Statutory authority / major-questions (either direction) — “Congress never granted the SEC the power to implement a sweeping, economy-wide
climate-related reporting regime.” CAPFORM Market efficiency / capital formation — “high compliance costs deter capital formation, discourage companies from going or staying public
and disproportionately burden smaller firms.” CB Compliance burden — “burdening public companies with excessive climate-related costs, including tracking,
auditing, reporting, scenario analysis, and obtaining third-party attestations for complex asset networks.” CBA Cost-benefit assessment — “duty to ensure that disclosure
mandates do not impose economic burdens that outweigh their informational benefits.” IMMAT Immaterial / not decision-useful — “This non-essential data may obscure information that is truly material
to reasonable investors, and overwhelm them with unnecessary, non-financial information.” INSUFF Insufficient / incoherent legal basis (either direction) — “The 2024 CDR requires prescriptive climate-related information, including
highly speculative information that is prioritized above other risks.” | |||||
| ▸195 | Aug. 3, 2026 | Peter J. Germain, Chief Legal Officer, Federated Hermes, Inc. | Support rescission | Investor / asset manager (institutional) | CAPFORM CB CBA CFR IMMAT IP REDUN |
Position: Support 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 — “maintaining the global competitiveness
of U.S. capital markets” CB Compliance burden — “Disclosure of non-material
information increases compliance costs and disclosure volume without improving investor
understanding” CBA Cost-benefit assessment — “Regulatory requirements that
impose significant costs while producing limited decision-useful information can ultimately harm
both issuers and investors” CFR Climate-related financial risk — “climate-related risks and opportunities may be
financially material to issuers and investors” IMMAT Immaterial / not decision-useful — “may compel disclosure of information that is
not material to a particular issuer or industry” IP Investor protection / decision usefulness — “we continue to believe investors benefit from consistent, comparable, and reliable
disclosure of material climate-related risks and opportunities” REDUN Redundant — existing rules, materiality regime, or voluntary reporting already suffice — “the Commission's longstanding principles-based disclosure requirements already provide an
appropriate framework for companies to disclose material climate-related risks” | |||||
| ▸194 | Aug. 3, 2026 | Andrew Langer, President, Main Street Foundation | Support rescission | Business trade association / advocacy org | 1A AUTH CAPFORM CB CBA CFR CMP DEMAND FRAG IMMAT INSUFF IP PP REDUN |
Position: Support rescission (unanimous) · Entity: Business trade association / advocacy org (unanimous) Modification posture: No modification requested — no substantive request to change the framework 1A Compelled speech / First Amendment (either direction) — “THE RULES RAISE SERIOUS COMPELLED-SPEECH CONCERNS” AUTH Statutory authority / major-questions (either direction) — “The federal securities statutes do not give the SEC unlimited authority to compel
information concerning any subject that some investors consider useful” CAPFORM Market efficiency / capital formation — “protect investors, maintain fair and efficient markets, and facilitate capital formation” CB Compliance burden — “Companies must design systems, assign personnel, develop
controls, obtain outside expertise, oversee third parties, and manage legal risk” CBA Cost-benefit assessment — “the Commission did not demonstrate informational benefits sufficient to
justify the rules’ full direct, indirect, and opportunity costs” CFR Climate-related financial risk — “New environmental regulations may increase costs or strand assets” CMP Standardization / comparability — “Standardization, however, can harmonize presentation without harmonizing the
underlying facts, assumptions, or methodologies” DEMAND Investor demand / fund reliance — “Investor demand cannot substitute for congressional authorization.” FRAG Regulatory fragmentation / multi-jurisdictional consistency — “Public companies may face
federal environmental reporting, financial-regulatory expectations, state climate mandates,
foreign disclosure regimes, procurement conditions, contractual demands, and voluntary
reporting frameworks simultaneously” IMMAT Immaterial / not decision-useful — “Numerical presentation may create a misleading appearance of precision when the
underlying information remains speculative, assumption-dependent, and difficult
for companies, auditors, and investors to verify” INSUFF Insufficient / incoherent legal basis (either direction) — “That authority carries a corresponding
responsibility to explain the change through reasoned decision-making.” IP Investor protection / decision usefulness — “material significance to reasonable investors” PP Political pressure / regulatory capture — “The Biden administration’s whole-of-government climate strategy could not enlarge” REDUN Redundant — existing rules, materiality regime, or voluntary reporting already suffice — “Existing disclosure requirements already capture climate-related regulation,
litigation, physical damage, supply interruption, insurance exposure, technological
developments, and market changes when those matters materially affect a
particular issuer” | |||||
| ▸193 | Aug. 3, 2026 | Charlotte Lorthioir | Oppose rescission | Individual | AUTH CBA CFR ENV INSUFF IP |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework AUTH Statutory authority / major-questions (either direction) — “I strongly disagree that requiring climate-relation information was an overreach of the Commission's statutory authority under Section 7(a)(1)” CBA Cost-benefit assessment — “The benefits provided to the public and shareholders far outweigh the reporting costs.” CFR Climate-related financial risk — “does have relevance to financial materiality given the increasing damage from climate change” ENV Environmental impact / consequences — “The United States is experiencing a climate crisis, where heat-related injuries and death are on the rise.” INSUFF Insufficient / incoherent legal basis (either direction) — “The arguments supporting the recission of the March 2024 climate disclosure rules are inherently flawed.” IP Investor protection / decision usefulness — “necessary or appropriate in the public interest or for the protection of investors” | |||||
| ▸192 | Aug. 3, 2026 | Barbara Davidson, Head of Capital Markets Transparency, Carbon Tracker | Oppose rescission | Environmental / ESG advocacy org | ACCT AUTH CAPFORM CFR CMP DEMAND ENV IP GHG12 GHG3 GOV TARGETS FINSTMT |
Position: Oppose rescission (unanimous) · Entity: Environmental / ESG advocacy org (unanimous) Modification posture: No modification requested — no substantive request to change the framework Keep provisions: GHG12 (Scope 1 & 2 emissions), GHG3 (Scope 3 emissions), GOV (Governance / risk management), TARGETS (Targets / transition plan), FINSTMT (Financial-statement effects (Reg S-X Art. 14)) ACCT Stewardship / accountability — “We support the SEC’s proposed rules that would require registrants to report on board- and management-level
oversight and responsibilities related to climate-related risks” AUTH Statutory authority / major-questions (either direction) — “We agree that the 1% threshold is well within the Commission’s authority.” CAPFORM Market efficiency / capital formation — “the Final Rules can promote
market integrity, facilitate capital formation and protect investors” CFR Climate-related financial risk — “The energy transition poses financial threats to incumbent firms.” CMP Standardization / comparability — “without comparable disclosures, investors cannot reliably assess and efficiently price how the
same risks affect the two companies’ balance sheets” DEMAND Investor demand / fund reliance — “seek more detailed, reliable, consistent and comparable climate-
related disclosures” ENV Environmental impact / consequences — “evidence for the significance of climate change is all around us and has been well-
documented” IP Investor protection / decision usefulness — “investors had access to more complete, reliable and comparable
information with which to make informed investment and voting decisions” | |||||
| ▸191 | Aug. 3, 2026 | Erik Sherman | Oppose rescission | Individual | DEMAND IP |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework DEMAND Investor demand / fund reliance — “investors have said they need climate change information” IP Investor protection / decision usefulness — “significant impact on their investment strategies and decisions” | |||||
| ▸190 | Aug. 3, 2026 | Lucas Penfold, Head of Sustainability Reporting, Impax Asset Management | Oppose rescission | Investor / asset manager (institutional) | ACCT AUTH CAPFORM CBA 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 — “conduct stewardship and allocate capital on behalf of our
clients” AUTH Statutory authority / major-questions (either direction) — “That is squarely within the SEC’s investor protection mandate.” CAPFORM Market efficiency / capital formation — “We believe transparent markets support capital formation. Reliable disclosure reduces information
asymmetry, helps investors price risk more accurately and supports more efficient allocation of capital.” CBA Cost-benefit assessment — “We recognise that disclosure has costs. However, those costs should be considered
alongside the costs imposed on investors when reliable information is unavailable.” CFR Climate-related financial risk — “Climate-related risks are financially material risks that already affect
company strategy, capital allocation, asset values, supply chains, operating costs and long-term
competitiveness.” CMP Standardization / comparability — “A consistent disclosure framework helps investors
identify and assess these risks, compare companies on a like-for-like basis, and make more informed
judgements about their financial materiality.” DEMAND Investor demand / fund reliance — “We supported the SEC’s original climate disclosure proposal because it recognised that investors
cannot make well-informed decisions without access to consistent, decision-useful information about
material climate-related risks.” FRAG Regulatory fragmentation / multi-jurisdictional consistency — “Retaining a clear US framework would help reduce fragmentation and provide
greater certainty for both investors and issuers operating across jurisdictions.” IP Investor protection / decision usefulness — “Investors need clear, comparable and reliable disclosure to assess those risks.” | |||||
| ▸189 | Aug. 3, 2026 | Robin Suydam, Director, Franklin Mutual Insurance Company Group | Oppose rescission | Issuer / Corporate — current | Modify / Expand CFR IP |
Position: Oppose rescission (unanimous) · Entity: Issuer / Corporate — current (unanimous) Modification posture: Modify / Expand — asks for stronger or broader disclosure CFR Climate-related financial risk — “Climate change is the largest challenge to property insurers in the country.” IP Investor protection / decision usefulness — “we have some ability to assess the risks involved in investments overseen by the SEC” | |||||
| ▸188 | Aug. 3, 2026 | Linda Sundberg, Head of Sustainable Investing, The Church of Sweden | Oppose rescission | Investor / asset manager (institutional) | Fallback / Compromise ACCT AUTH CB CBA CFR CMP DEMAND ENV FRAG INSUFF IP 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 — “Governance and risk-oversight disclosures, and Scope 1 and Scope 2 emissions reporting for large
accelerated and accelerated filers, rest on the same footing as other risk-factor and MD&A disclosures” AUTH Statutory authority / major-questions (either direction) — “Even if the Commission were to conclude that narrower authority
questions exist as to specific provisions, that is a reason to address those provisions individually through
the administrative process.” CB Compliance burden — “those costs are greatly mitigated when issuers have a template to follow, adding certainty
surrounding disclosure obligations and reduced compliance risks.” CBA Cost-benefit assessment — “emphasizes the compliance costs registrants would avoid,
but that analysis is misleading.” CFR Climate-related financial risk — “physical risks to facilities and supply chains, transition risks tied to energy-intensive operations,
and regulatory exposure in carbon-priced jurisdictions.” CMP Standardization / comparability — “consistent,
comparable and decision-useful climate disclosures to assess both risks and opportunities across our
portfolios.” DEMAND Investor demand / fund reliance — “institutional investors representing tens of trillions of dollars in assets have told the Commission,” ENV Environmental impact / consequences — “prioritize engagement with companies where investor influence
can contribute to real-world emissions reductions and support a just transition.” FRAG Regulatory fragmentation / multi-jurisdictional consistency — “International
Sustainability Standards Board-aligned S2 disclosure regimes adopted by other jurisdictions in which
they operate or list.” INSUFF Insufficient / incoherent legal basis (either direction) — “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 our fundamental research, valuation, and risk management
processes.” | |||||
| ▸187 | Aug. 3, 2026 | Carine Smith Ihenacho, Chief Governance and Compliance Officer, and Snorre Gjerde, Policy Lead, Norges Bank Investment Management | Oppose rescission | Investor / asset manager (institutional) | Fallback / Compromise CAPFORM CB CBA CFR CMP DEMAND FRAG IP |
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 — “support the international competitiveness of U.S.
companies” CB Compliance burden — “reduce compliance burden for technically demanding elements” CBA Cost-benefit assessment — “without imposing undue
cost or duplication on reporting companies” CFR Climate-related financial risk — “Climate risk can affect asset prices through multiple
channels that influence individual companies’ business and financial characteristics” CMP Standardization / comparability — “consistent, comparable and reliable information
on how individual companies are exposed” DEMAND Investor demand / fund reliance — “Without such information, investors are reliant on own estimates or third-party data which cannot fully
substitute for direct company disclosure” FRAG Regulatory fragmentation / multi-jurisdictional consistency — “closer alignment with international standards for climate-related
reporting” IP Investor protection / decision usefulness — “informs our investment decisions, shareholder voting
and risk management processes” | |||||
| ▸186 | Aug. 3, 2026 | Jason Isaac, President, American Energy Association | Support rescission | Business trade association / advocacy org | 1A AUTH CAPFORM CB FRAG IMMAT INSUFF IP REDUN |
Position: Support rescission (unanimous) · Entity: Business trade association / advocacy org (unanimous) Modification posture: No modification requested — no substantive request to change the framework 1A Compelled speech / First Amendment (either direction) — “adopt frameworks and convey messages they may reject or prefer to leave unsaid.” AUTH Statutory authority / major-questions (either direction) — “The rule lacks statutory foundation.” CAPFORM Market efficiency / capital formation — “core responsibilities of investor protection, capital formation, and the maintenance” CB Compliance burden — “scenario analysis, emissions-estimation methodologies, climate-specific” FRAG Regulatory fragmentation / multi-jurisdictional consistency — “further state that its rescission of the rule preempts state attempts to require similar disclosures.” IMMAT Immaterial / not decision-useful — “The rule fails that test.” INSUFF Insufficient / incoherent legal basis (either direction) — “Nor did the record identify any genuine problem for the rule to solve.” IP Investor protection / decision usefulness — “information reaches the market to inform investment and voting decisions” REDUN Redundant — existing rules, materiality regime, or voluntary reporting already suffice — “issuers routinely furnish substantial climate-related information voluntarily where” | |||||
| ▸185 | Aug. 3, 2026 | Benjamin Zycher, Senior Fellow, American Enterprise Institute | Support rescission | Business trade association / advocacy org | AUTH CAPFORM CB CBA CFR ENV IMMAT INSUFF PP REDUN |
Position: Support rescission (unanimous) · Entity: Business trade association / advocacy org (unanimous) Modification posture: No modification requested — no substantive request to change the framework AUTH Statutory authority / major-questions (either direction) — “The major questions doctrine reduces the likelihood of such agency actions further, as does the
end of Chevron deference.” CAPFORM Market efficiency / capital formation — “resulting in a misallocation of capital and a reduction in aggregate
economic performance, with no measurable climate benefits” CB Compliance burden — “Disclosure of climate “risks” would require thousands of pages of analysis based upon tens of
thousands of pages of supporting documentation” CBA Cost-benefit assessment — “The 2024 rule cannot satisfy any
plausible benefit/cost test, and should be discarded.” CFR Climate-related financial risk — “the prospective financial risks of
anthropogenic climate change, at least in the aggregate, are much smaller than many assert” ENV Environmental impact / consequences — “there is no evidence in support of the ubiquitous assertions of a climate “crisis,” whether
ongoing or looming” IMMAT Immaterial / not decision-useful — “Firm-specific greenhouse gas emissions, even if defined broadly, are not material
information for investors because such firm-specific emissions would yield climate impacts
effectively equal to zero.” INSUFF Insufficient / incoherent legal basis (either direction) — “No plausible list of SEC areas of expertise includes climate science and policy” PP Political pressure / regulatory capture — “This would represent
the return of Operation Choke Point, an illegal past attempt to politicize access to capital” REDUN Redundant — existing rules, materiality regime, or voluntary reporting already suffice — “Because the SEC already requires disclosure of risks material to the given firm, we must
ask what the SEC is trying to achieve.” | |||||
| ▸184 | Aug. 3, 2026 | Americans for Financial Reform Education Fund, Public Citizen, and 35 Organizations | Oppose rescission | Environmental / ESG advocacy org | AUTH CAPFORM CFR CMP DEMAND FRAG IP PP |
Position: Oppose rescission (unanimous) · Entity: Environmental / ESG advocacy org (majority) Modification posture: No modification requested — no substantive request to change the framework AUTH Statutory authority / major-questions (either direction) — “The SEC has clear and specific authority and responsibility to require standardized, comparable” CAPFORM Market efficiency / capital formation — “maintain smooth functioning of the
capital markets” CFR Climate-related financial risk — “Climate change is a growing source of financial risk for public companies and investors” CMP Standardization / comparability — “consistent, comparable, and decision-useful information” DEMAND Investor demand / fund reliance — “nearly unanimous support from
institutional investors managing over $50 trillion in” FRAG Regulatory fragmentation / multi-jurisdictional consistency — “jurisdictions representing over half of global GDP” IP Investor protection / decision usefulness — “market participants need to assess public companies” PP Political pressure / regulatory capture — “an “early gift” to the fossil fuel
industry which had” | |||||
| ▸183 | Aug. 3, 2026 | Lynn Paquin, Senior Portfolio Manager, California State Teachers' Retirement System (CalSTRS) | Oppose rescission | Investor / asset manager (institutional) | ACCT AUTH CAPFORM CBA CFR CMP DEMAND IP GHG12 TARGETS FINSTMT |
Position: Oppose rescission (unanimous) · Entity: Investor / asset manager (institutional) (unanimous) Modification posture: No modification requested — no substantive request to change the framework Keep provisions: GHG12 (Scope 1 & 2 emissions), TARGETS (Targets / transition plan), FINSTMT (Financial-statement effects (Reg S-X Art. 14)) ACCT Stewardship / accountability — “The absence of reliable data has directly impaired our ability to execute our
stewardship activities.” AUTH Statutory authority / major-questions (either direction) — “We urge the Commission to reconsider its statutory authority argument.” CAPFORM Market efficiency / capital formation — “Its rescission would represent a
significant step backward for investors, markets, and the integrity of the Commission’s
disclosure framework.” CBA Cost-benefit assessment — “The Commission’s assertion that the Climate Disclosure Rule “imposes substantial costs”
must be weighed against the significant costs investors like CalSTRS already bear in the
absence of standardized disclosure.” CFR Climate-related financial risk — “Climate risk is financial risk. The physical and transition risks associated
with climate change have direct, measurable impacts on the value of the companies we
own across every sector of the economy.” CMP Standardization / comparability — “individually assessing each company’s climate risk exposure is not feasible
without the kind of standardized, machine-readable data disclosed within SEC filings” DEMAND Investor demand / fund reliance — “We requested
that the Commission prioritize mandatory Scope 3 emissions disclosure for all registrants,
require attestation of greenhouse gas emissions across all filer categories, and use the
International Sustainability Standards Board’s (ISSB) Climate Standard as the foundation
for its rulemaking.” IP Investor protection / decision usefulness — “deprive long-term institutional investors like CalSTRS of the reliable, consistent, and
comparable climate-related financial information we need to fulfill our fiduciary duties” | |||||
| ▸128 | August 3, 2026 | Woodwell Climate Research Center | Oppose rescission | Environmental / ESG advocacy org | Modify / Improve or Clarify AUTH CAPFORM CB CBA CFR CMP DEMAND ENV FRAG INSUFF IP PP |
Position: Oppose rescission (unanimous) · Entity: Environmental / ESG advocacy org (unanimous) Modification posture: Modify / Improve or Clarify — asks for a revised, clarified or better-designed framework AUTH Statutory authority / major-questions (either direction) — “15 former senior SEC officials, 17
senior scholars of corporate, securities, and administrative law” CAPFORM Market efficiency / capital formation — “improved asset pricing and allocation of capital” CB Compliance burden — “This process will better reflect an effort to protect investors and benefit the economy, as
opposed to rescinding the Final Rules in their entirety” CBA Cost-benefit assessment — “the SEC highlights the increased costs on
registrants as a result of the Final Rules while negating the increased costs on investors as a result of the
rescission” CFR Climate-related financial risk — “Climate risk is business risk, and climate risk is financial risk” CMP Standardization / comparability — “Disclosure and the concepts of materiality, comparability, flexibility, efficiency and responsibility have” DEMAND Investor demand / fund reliance — “95
percent of the 320 institutional investors who issued a public comment supported its key provisions” ENV Environmental impact / consequences — “Winter
storms, extreme precipitation, and summer heat waves are just some examples of these increasingly
frequent and intense weather patterns” FRAG Regulatory fragmentation / multi-jurisdictional consistency — “Other governing bodies such as the European Union and the State of California have already implemented
their own climate-related financial disclosure rules in attempts to align with the ISSB” INSUFF Insufficient / incoherent legal basis (either direction) — “The judge in this case determined that without adequate evidence or explanation of the disregard of the factual
findings of the previous policy, the rescission was “arbitrary and capricious.”” IP Investor protection / decision usefulness — “Investors also show wide-reaching recognition of the importance of climate-related disclosures” PP Political pressure / regulatory capture — “The short-term political interests that color this proposed rescission do not usurp the decades of precedent” | |||||
| ▸127 | August 3, 2026 | Amy D. Augustine, Director, and Kristen Lang, Deputy Director, ESG Investing, Boston Trust Walden National Association | Oppose rescission | Investor / asset manager (institutional) | Fallback / Compromise ACCT AUTH CAPFORM CB CBA CFR CMP DEMAND FRAG IP GHG12 GOV 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), TARGETS (Targets / transition plan) ACCT Stewardship / accountability — “We support the Final Rules' requirement under provision 1501(a) to disclose board and management oversight of climate risks” AUTH Statutory authority / major-questions (either direction) — “the Final Rules are disclosure rules, not regulatory rules. They do not require
companies to disclose whether or how they should respond to the perceived causes and effects of
climate change” CAPFORM Market efficiency / capital formation — “the lack of a US federal regulatory disclosure mandate could result in
information asymmetry across capital markets, increasing US companies' cost of capital” CB Compliance burden — “These processes for gathering necessary climate-related
disclosures to gain a comprehensive understanding of a company's risk profile are inefficient and
resource intensive” CBA Cost-benefit assessment — “the Commission's articulation of cost savings fails to account for the significant costs transferred to shareholders in the
absence of a US federal regulatory disclosure mandate” CFR Climate-related financial risk — “Climate risk is
relevant to nearly all industries, manifesting itself in a variety of ways and over varying time horizons,
with the potential to impact all investor types” CMP Standardization / comparability — “high-quality, decision-useful, and
standardized climate-related disclosures are essential to ensure completeness, consistency, and
comparability in our analysis” DEMAND Investor demand / fund reliance — “investors representing more than
$54 trillion in assets under management” FRAG Regulatory fragmentation / multi-jurisdictional consistency — “as US companies are increasingly compelled to provide climate risk-related disclosures in
other global markets” IP Investor protection / decision usefulness — “investors can continue to efficiently assess risk and opportunity management, allocate capital, and make informed voting
decisions” | |||||
| ▾ August 2, 2026 11 letters | |||||
| ▸708 | Aug. 2, 2026 | Jamie Bonham, Head of Responsible Investing, NEI Investments | Oppose rescission | Investor / asset manager (institutional) | Modify / Improve or Clarify AUTH CAPFORM CB CBA CFR CMP DEMAND FRAG INSUFF IP |
Position: Oppose rescission (unanimous) · Entity: Investor / asset manager (institutional) (unanimous) Modification posture: Modify / Improve or Clarify — asks for a revised, clarified or better-designed framework AUTH Statutory authority / major-questions (either direction) — “we would disagree with the characterization that mandating this form of disclosure is beyond the SEC's statutory authority” CAPFORM Market efficiency / capital formation — “Mandatory disclosure will address a key market failure” CB Compliance burden — “to minimize the reporting burden for issuers” CBA Cost-benefit assessment — “It would not be prudent to abandon the Rules in their entirety to protect such companies from burdensome requirements when the SEC has readily available tools to address these concerns.” CFR Climate-related financial risk — “These are real, material risks facing companies and their investors” CMP Standardization / comparability — “it ultimately falls short due to the lack of standardization and uniformity” DEMAND Investor demand / fund reliance — “Evidence of investor-demand for climate-related disclosure is everywhere.” FRAG Regulatory fragmentation / multi-jurisdictional consistency — “to ensure comparability across jurisdictions and to minimize the reporting burden for issuers” INSUFF Insufficient / incoherent legal basis (either direction) — “but these arguments were raised in the initial, and comprehensive, consultations that led to the development of the Rules” IP Investor protection / decision usefulness — “decision-useful, material information pertaining to those assets” | |||||
| ▸182 | Aug. 2, 2026 | Peter Kellogg, Student | Oppose rescission | Student | Fallback / Compromise AUTH CAPFORM CBA CFR CMP FRAG INSUFF IP WHIP FINSTMT GHG12 |
Position: Oppose rescission (unanimous) · Entity: Student (majority) 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) AUTH Statutory authority / major-questions (either direction) — “I quarrel with the conclusion, because climate-related disclosure satisfies them.” CAPFORM Market efficiency / capital formation — “investors' ability to price long-horizon risk accurately” CBA Cost-benefit assessment — “That is not a complete economic analysis” CFR Climate-related financial risk — “Losses from severe weather events flow directly through the income statement” CMP Standardization / comparability — “defeat cross-company comparison” FRAG Regulatory fragmentation / multi-jurisdictional consistency — “European Union's Corporate Sustainability Reporting Directive” INSUFF Insufficient / incoherent legal basis (either direction) — “the proposal does not carry that burden” IP Investor protection / decision usefulness — “decision-useful risk information” WHIP Regulatory whiplash / reliance interests / costs already incurred — “Large accelerated filers spent 2024 and 2025 building” | |||||
| ▸181 | Aug. 2, 2026 | David Apatoff | Oppose rescission | Individual | ACCT CAPFORM ENV FRAG IP |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework ACCT Stewardship / accountability — “The SEC has no business intervening to protect corporations and telling shareholders that we should not want the information that we want.” CAPFORM Market efficiency / capital formation — “If you truly believe in a free market as you claim you do, let the providers of capital (the shareholders) get access to reliable information on this crucial issue.” ENV Environmental impact / consequences — “The excruciating heat conditions the world is now experiencing make your efforts to protect corporate management even more shameful.” FRAG Regulatory fragmentation / multi-jurisdictional consistency — “Corporations are already fleeing, in a race to the bottom, from Delaware to more and more permissive states such as Texas, and federal standards are the only remaining source of reliability.” IP Investor protection / decision usefulness — “shareholders are desperately in need of accurate and reliable information from corporations” | |||||
| ▸180 | Aug. 2, 2026 | Janet Buschert | 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 — “It is important for companies to report on their climate change impacts.” IP Investor protection / decision usefulness — “could impact investor behavior both short term and long term” | |||||
| ▸179 | Aug. 2, 2026 | Donald Isaacs | 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 — “We investors need and deserve information on climate change.” | |||||
| ▸178 | Aug. 2, 2026 | Debra Axness | Oppose rescission | Individual | DEMAND IP |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework DEMAND Investor demand / fund reliance — “Investors (and everyone else in our country) want and deserve information on climate change” IP Investor protection / decision usefulness — “want and deserve information on climate change” | |||||
| ▸177 | Aug. 2, 2026 | Anonymous | Oppose rescission | Individual | CAPFORM CFR CMP 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 — “promote transparent, efficient markets” CFR Climate-related financial risk — “Global climate change (GCC) presents considerable risks to our financial systems.” CMP Standardization / comparability — “provide much needed consistent reporting on the effects of GCC that businesses and investors would face with any given project” ENV Environmental impact / consequences — “how their operations contribute to climate change and their plans to reduce that pollution” IP Investor protection / decision usefulness — “The information required by the CCDR would be of great use to investors, financial markets, and companies.” | |||||
| ▸176 | Aug. 2, 2026 | Nell Minow, Chair, ValueEdge Advisors | Oppose rescission | Investor / asset manager (institutional) | ACCT AUTH CAPFORM CBA CFR CMP DEMAND FRAG INSUFF IP PP |
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 — “Boards need the environmental risk disclosures” AUTH Statutory authority / major-questions (either direction) — “the climate disclosure rules are clearly within the Commission” CAPFORM Market efficiency / capital formation — “increase the cost of capital and make” CBA Cost-benefit assessment — “The claimed costs are exaggerated and unsupported” CFR Climate-related financial risk — “increased credit risk” CMP Standardization / comparability — “consistent, comparable, and reliable” DEMAND Investor demand / fund reliance — “investors tell you they need” FRAG Regulatory fragmentation / multi-jurisdictional consistency — “Task Force on Climate-related Financial Disclosures (TCFD) framework” INSUFF Insufficient / incoherent legal basis (either direction) — “particularly vulnerable to challenge in court” IP Investor protection / decision usefulness — “vital importance to investors in evaluating risk” PP Political pressure / regulatory capture — “all from one party” | |||||
| ▸175 | Aug. 2, 2026 | Trevar Kolodny, Visiting Fellow, Sarah Wagoner, Policy Analyst, Environmental and Energy Policy, and Michael Bicksel, YLP Intern, The Heritage Foundation | Support rescission | Business trade association / advocacy org | AUTH CAPFORM CB CBA FRAG IMMAT INSUFF IP PP REDUN |
Position: Support rescission (unanimous) · Entity: Business trade association / advocacy org (unanimous) Modification posture: No modification requested — no substantive request to change the framework AUTH Statutory authority / major-questions (either direction) — “The SEC should therefore repeal the 2024 climate disclosure rule as far exceeding any express
Congressional delegation of power found in the enabling statutes.” CAPFORM Market efficiency / capital formation — “The number of publicly traded companies has decreased approximately 50 percent since
1997, when more than 7,300 U.S. companies were listed publicly, compared to approximately
3,700 today.” CB Compliance burden — “firms would devote substantial effort to implementing new
reporting systems, reviewing disclosures, and maintaining ongoing compliance.” CBA Cost-benefit assessment — “The SEC’s cost savings estimates appear reasonable, but in several respects they may be
overly conservative.” FRAG Regulatory fragmentation / multi-jurisdictional consistency — “some multinational issuers may continue to collect climate-related information
to comply with foreign or state disclosure requirements, those firms would nevertheless benefit
from avoiding duplicative SEC-specific reporting obligations” IMMAT Immaterial / not decision-useful — “immaterial climate disclosures are not covered within the authorizing statutes.” INSUFF Insufficient / incoherent legal basis (either direction) — “the Government is
entitled to “conclude that reliance interests in benefits that it views as unlawful are entitled to no
or diminished weight.” IP Investor protection / decision usefulness — “We therefore ask whether the failure to
include the climate disclosures the SEC mandated would mislead investors—and again answer
that it would not.” PP Political pressure / regulatory capture — “this guidance suggests an
attempt by the SEC to promote a political agenda through regulation.” REDUN Redundant — existing rules, materiality regime, or voluntary reporting already suffice — “unnecessary, given that publicly listed companies are required to disclose
material information even absent the 2024 Final Rule.” | |||||
| ▸174 | Aug. 2, 2026 | Abbie Rachel Bernstein | 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 — “lying about or obfuscating the causes will not help us survive.” ENV Environmental impact / consequences — “We can tell what's happening to the climate - lying about or obfuscating the causes will not help us survive.” | |||||
| ▸173 | Aug. 2, 2026 | Rebecca Guthrie | Oppose rescission | Individual | ACCT CAPFORM ENV IP |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework ACCT Stewardship / accountability — “Do not allow corporations to hide” CAPFORM Market efficiency / capital formation — “Rescinding this rule would be a step backward for U.S. markets” ENV Environmental impact / consequences — “climatic repercussions of their practice” IP Investor protection / decision usefulness — “millions of Americans whose financial futures depend on their investments” | |||||
| ▾ August 1, 2026 10 letters | |||||
| ▸707 | Aug. 1, 2026 | Susan Jordan, SSND | Oppose rescission | Investor / asset manager (institutional) | ACCT AUTH CB CBA CFR CMP DEMAND 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 — “engage with many corporations on their environmental and social impacts, and on strong governance practices” AUTH Statutory authority / major-questions (either direction) — “it somehow lacks the authority to do what Congress charged it to do” CB Compliance burden — “the Rules are not unduly burdensome to companies” CBA Cost-benefit assessment — “we and other investors and companies would benefit from the standardized, comparable, mandatory disclosures” CFR Climate-related financial risk — “the risks to company operations posed by climate-related disclosures” CMP Standardization / comparability — “produces consistent, comparable, reliable disclosures” DEMAND Investor demand / fund reliance — “Institutional investors representing many trillions of dollars in assets have told the Commission across multiple comment cycles since 2021” INSUFF Insufficient / incoherent legal basis (either direction) — “the release fails to counter the Commission's prior finding that the rule, as adopted, produces consistent, comparable, reliable disclosures” IP Investor protection / decision usefulness — “decision-useful and, for many, material” | |||||
| ▸172 | Aug. 1, 2026 | Bingham Kennedy, Former EPA and Justice Department 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 — “America to avoid accountability for the environmental impacts of its” ENV Environmental impact / consequences — “Raging wildfires enhanced by rising temperatures in forests and” IP Investor protection / decision usefulness — “As an investor, I consider climate-related information extremely important” | |||||
| ▸171 | Aug. 1, 2026 | Sherman Dorn | Oppose rescission | Individual | ACCT AUTH CAPFORM CFR CMP IP |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework ACCT Stewardship / accountability — “have relied on the obligations of the companies I own to report the fair economic and business conditions of their companies” AUTH Statutory authority / major-questions (either direction) — “was reasonable, appropriate, and in line with the history of SEC obligations” CAPFORM Market efficiency / capital formation — “so that capital markets can get as close to efficiency as possible” CFR Climate-related financial risk — “The expansion of reporting obligations to climate conditions that affect the foreseeable conditions affecting a company was reasonable” CMP Standardization / comparability — “depends on a standard set of rules that over time expand the reporting obligations” IP Investor protection / decision usefulness — “information about economic conditions of public companies is reported properly, frequently, comprehensively” | |||||
| ▸170 | Aug. 1, 2026 | Kathleen Doyle | 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 change is a significant risk that should be disclosed along with the other significant risks that a company faces.” IP Investor protection / decision usefulness — “Investors deserve to know the risks and outlook for companies that sell shares in the US.” | |||||
| ▸169 | Aug. 1, 2026 | Thomas Nieland | 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. | |||||
| ▸168 | Aug. 1, 2026 | Cathy Becker, Responsible Finance Campaign Director, and Todd Larsen, Executive Co-Director, Green America | Oppose rescission | Environmental / ESG advocacy org | ACCT AUTH CAPFORM CBA CFR CMP DEMAND ENV INSUFF IP PP |
Position: Oppose rescission (unanimous) · Entity: Environmental / ESG advocacy org (unanimous) Modification posture: No modification requested — no substantive request to change the framework ACCT Stewardship / accountability — “How their board of directors was managing these risks.” 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 — “maintain fair, orderly,
and efficient markets; and facilitate capital formation.” CBA Cost-benefit assessment — “Imposes costs not justified by benefits.” CFR Climate-related financial risk — “Material climate-related risks.” CMP Standardization / comparability — “Investors have long sought consistent and comparable climate risk disclosure” DEMAND Investor demand / fund reliance — “over 15,000 people
signed a Green America petition supporting the rule and asking the SEC to make it even
stronger.” ENV Environmental impact / consequences — “environmental impacts and provide greater transparency for investment
decisions.” INSUFF Insufficient / incoherent legal basis (either direction) — “The rationale for rescinding the rule misinterprets both history and law” IP Investor protection / decision usefulness — “investors for
the first time would have reliable and comparable information about how companies are
handling climate-related financial risks and opportunities” 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.” | |||||
| ▸167 | Aug. 1, 2026 | George L. Pollard | Oppose rescission | Individual | INSUFF |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework INSUFF Insufficient / incoherent legal basis (either direction) — “The rationale for doing this is shallow” | |||||
| ▸166 | Aug. 1, 2026 | Andrew Howard, Global Head of Sustainable Investment, Schroders plc | Mixed | Investor / asset manager (institutional) | Modify / Reduce ACCT CAPFORM CB CBA CFR CMP FRAG INSUFF IP WHIP GHG12 GOV |
Position: Mixed (unanimous) · Entity: Investor / asset manager (institutional) (unanimous) Modification posture: Modify / Reduce — asks for fewer or more limited requirements Keep provisions: GHG12 (Scope 1 & 2 emissions), GOV (Governance / risk management) ACCT Stewardship / accountability — “simplified governance disclosure consistent with the Item 407(h) approach” CAPFORM Market efficiency / capital formation — “plausibly a deterrent to listing or remaining so.” CB Compliance burden — “burden falls most heavily on smaller registrants least” CBA Cost-benefit assessment — “reduce aggregate annual cost from ~US$4.9 billion to, on our indicative estimate, materially below US$1 billion,” CFR Climate-related financial risk — “physical and transition impacts affect cash flows, asset values and the cost of capital” CMP Standardization / comparability — “decreasing data acquisition costs and improving data reliability and” FRAG Regulatory fragmentation / multi-jurisdictional consistency — “those obligations to state and foreign regimes, and fragment the standards US companies must meet.” INSUFF Insufficient / incoherent legal basis (either direction) — “the skew of compliance cost toward smaller registrants, which is avoidable through scoping rather than” IP Investor protection / decision usefulness — “enhancing the ability of investors to make prudent investment decisions” WHIP Regulatory whiplash / reliance interests / costs already incurred — “Registrants and market participants invested in measurement, assurance readiness and data” | |||||
| ▸165 | Aug. 1, 2026 | Mark Canright | Oppose rescission | Individual | AUTH CAPFORM CBA ENV FRAG IP |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework AUTH Statutory authority / major-questions (either direction) — “the rule falls well within the agency's statutory authority” CAPFORM Market efficiency / capital formation — “Rescinding this rule would be a step backward for U.S. markets” CBA Cost-benefit assessment — “the benefits of standardized disclosure far outweigh the costs” ENV Environmental impact / consequences — “I care about protecting our environment and reversing harmful climate change” FRAG Regulatory fragmentation / multi-jurisdictional consistency — “More than 40 countries-representing 60 percent of global GDP-have approved or proposed climate disclosure rules of their own” IP Investor protection / decision usefulness — “the millions of Americans whose financial futures depend on their investments” | |||||
| ▸164 | Aug. 1, 2026 | Rebecca Canright | No position | Individual | ENV |
Position: No position (unanimous) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework ENV Environmental impact / consequences — “As a young person, I care a lot about protecting our environment.” | |||||
| ▾ July 31, 2026 38 letters | |||||
| ▸281 | July 31, 2026 | As You Sow | Oppose rescission | Environmental / ESG advocacy org | ACCT CAPFORM CBA CFR CMP DEMAND INSUFF IP |
Position: Oppose rescission (unanimous) · Entity: Environmental / ESG advocacy org (unanimous) Modification posture: No modification requested — no substantive request to change the framework ACCT Stewardship / accountability — “These disclosures
enable investors to assess whether boards and management are appropriately overseeing climaterelated financial risks” CAPFORM Market efficiency / capital formation — “Comparable disclosure enhances market efficiency by reducing information asymmetry,
improving price discovery, and lowering the overall cost of capital.” CBA Cost-benefit assessment — “The Commission's recission proposal likewise underestimates the significant economic
benefits of standardized disclosure while overstating compliance costs.” CFR Climate-related financial risk — “Climate-related risks increasingly affect
the entire range of business operations, from supply chain reliability to operating costs, insurance
availability, asset valuations, workforce productivity, regulatory compliance, access to capital,
agricultural productivity, and long-term corporate strategy” CMP Standardization / comparability — “Without consistent, comparable disclosure across issuers, investors are left to rely on
fragmented voluntary reports and third-party estimates that increase costs, reduce comparability,
and impair informed investment decision-making.” DEMAND Investor demand / fund reliance — “investors representing tens of trillions of dollars in
assets under management sought standardized climate-related disclosures because existing
voluntary reporting was inconsistent, incomplete, and difficult to compare across issuers” INSUFF Insufficient / incoherent legal basis (either direction) — “An agency
may change policy, but it must provide a reasoned explanation for departing from its prior
factual findings. The Commission's proposal fails to do so.” IP Investor protection / decision usefulness — “provide investors with essential and material information for evaluating how companies identify,
assess, and manage risks arising from physical climate impacts” | |||||
| ▸280 | July 31, 2026 | Carolyn Dann, Green Team Co-Chair, South Church of Andover | Oppose rescission | Environmental / ESG advocacy org | AUTH CB CFR CMP ENV FRAG IP |
Position: Oppose rescission (unanimous) · Entity: Environmental / ESG advocacy org (unanimous) Modification posture: No modification requested — no substantive request to change the framework 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 — “Climate risk is real even for a local church.” CMP Standardization / comparability — “South Church holds the strong view that citizens, investors and companies would benefit from the standardized,
comparable, mandatory disclosures that the structure of 2024 Rules provide.” ENV Environmental impact / consequences — “We believe that the environmental risks associated with climate” FRAG Regulatory fragmentation / multi-jurisdictional consistency — “mandatory disclosures for companies doing business
in California and the E.U., as well as voluntary sets of reporting standards” IP Investor protection / decision usefulness — “Climate-related disclosures are critical for effective Investment analysis and decision-making by companies as they plan” | |||||
| ▸163 | July 31, 2026 | Robin Suydam | Oppose rescission | Individual | Modify / Expand CAPFORM CFR IP |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: Modify / Expand — asks for stronger or broader disclosure CAPFORM Market efficiency / capital formation — “Those investing in American markets will be at a tremendous disadvantage - and at risk - compared to other global markets in the near and long term.” CFR Climate-related financial risk — “climate risk disclosure” IP Investor protection / decision usefulness — “As an investor, I urge the SEC to retain and fortify regs related to climate risk disclosure.” | |||||
| ▸162 | July 31, 2026 | Kevin Walsh | 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 — “We need accountability from big polluters.” ENV Environmental impact / consequences — “We need accountability from big polluters.” | |||||
| ▸161 | July 31, 2026 | Constance Minerovic | Oppose rescission | Individual | ACCT |
Position: Oppose rescission (majority) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework ACCT Stewardship / accountability — “We are ALL responsible for doing what is Best for the World!” | |||||
| ▸160 | July 31, 2026 | Lynn Hoang | Oppose rescission | Individual | AUTH CBA CMP |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework AUTH Statutory authority / major-questions (either direction) — “the rule falls well within the (SEC) agency's statutory authority” CBA Cost-benefit assessment — “the benefits of standardized disclosure far outweigh the costs” CMP Standardization / comparability — “standardized disclosure” | |||||
| ▸159 | July 31, 2026 | Fran Seegull, President, U.S. Impact Investing Alliance | Oppose rescission | Business trade association / advocacy org | ACCT AUTH CAPFORM CBA CFR CMP DEMAND FRAG INSUFF IP WHIP |
Position: Oppose rescission (unanimous) · Entity: Business trade association / advocacy org (unanimous) Modification posture: No modification requested — no substantive request to change the framework ACCT Stewardship / accountability — “hold corporate
management accountable” AUTH Statutory authority / major-questions (either direction) — “statutory-authority theory is excessively” CAPFORM Market efficiency / capital formation — “Diverging from this global baseline standard goes directly against the Commission’s stated
policy goal of facilitating capital formation” CBA Cost-benefit assessment — “State Farm34 requires the Commission to weigh both” CFR Climate-related financial risk — “climate-related risks are financial risks that reasonable investors consider material” CMP Standardization / comparability — “Mandatory, standardized disclosure permits investors to compare issuers on a like-for-like” DEMAND Investor demand / fund reliance — “Ceres of the comment letters submitted by 320 institutional investors” FRAG Regulatory fragmentation / multi-jurisdictional consistency — “Task Force on Climate-Related Financial Disclosures framework, the International Sustainability” INSUFF Insufficient / incoherent legal basis (either direction) — “the proposed rescission cannot survive
reasoned-decisionmaking review” IP Investor protection / decision usefulness — “price risk accurately, allocate capital” WHIP Regulatory whiplash / reliance interests / costs already incurred — “Reliance is not hypothetical: issuers have invested in building climate
data and reporting capabilities in anticipation of compliance” | |||||
| ▸158 | July 31, 2026 | Sarah Michele Taylor | Oppose rescission | Individual | ACCT CFR ENV IP |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework ACCT Stewardship / accountability — “Climate-related financial disclosure helps hold companies accountable for the environmental harm and externalities they create” CFR Climate-related financial risk — “Climate change poses a massive risk to companies and individuals across the country” ENV Environmental impact / consequences — “I also believe that rescinding the SEC's climate-related disclosure requirement will cause the United States to lag behind other countries globally in climate change mitigation and adaptation efforts” IP Investor protection / decision usefulness — “allows stakeholders to make more informed purchasing and investment decisions” | |||||
| ▸157 | July 31, 2026 | Thomas Saccardi, MBA, Ph.D., Retired Hospital Administrator; Retired Bond Insurance Officer | 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 — “Eliminating climate-related disclosure rules would be an economical and social tragedy!” | |||||
| ▸156 | July 31, 2026 | Lisa Hammermeister | 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 — “Transparency is the operative term.” | |||||
| ▸154 | July 31, 2026 | Yoshio Nishioka/Rainforest Action Group, HUTAN Group | 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 — “Seeing many big wild fires in USA,Canada, Spain, France, Greece, Turkish, anywhere,,,. WE must battle to make bad Global warming now.” | |||||
| ▸153 | July 31, 2026 | Thomas Hilliard | Oppose rescission | Individual | ENV FRAG IP |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework ENV Environmental impact / consequences — “Companies should take pride in how they affect the environment.” FRAG Regulatory fragmentation / multi-jurisdictional consistency — “More than 40 countries-representing 60 percent of global GDP-have approved or proposed climate disclosure rules of their own.” IP Investor protection / decision usefulness — “The U.S. should be a leader in transparency in stock and fund reporting.” | |||||
| ▸152 | July 31, 2026 | Susan Richman | Oppose rescission | Individual | ACCT CFR IP |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework ACCT Stewardship / accountability — “this information is necessary for due diligence in their financial stewardship” CFR Climate-related financial risk — “I will not invest in a company for which I do not know the prospective financial risks involved, and that includes the risks from the effects of climate change.” IP Investor protection / decision usefulness — “The Climate-Related Disclosure Rules have allowed my financial advisors to have information necessary for where to put the retirement funds” | |||||
| ▸151 | July 31, 2026 | Rev. Trella M. Davis | 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 | |||||
| ▸150 | July 31, 2026 | Patricia Rowell | Oppose rescission | Individual | FRAG IP |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework FRAG Regulatory fragmentation / multi-jurisdictional consistency — “More than 40 countries—representing 60 percent of global GDP—have approved or proposed climate disclosure rules of their own.” IP Investor protection / decision usefulness — “the millions of Americans whose financial futures depend on their investments” | |||||
| ▸149 | July 31, 2026 | Orianna Bretscher, CEO, Aquacycl | Oppose rescission | Individual | CAPFORM 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 — “global growth of new sectors” IP Investor protection / decision usefulness — “Climate-Related Disclosure Rules are important for transparency, investment” | |||||
| ▸148 | July 31, 2026 | MKT | 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 — “if you don't hold them accountable to do the work and disclose, they will not” ENV Environmental impact / consequences — “The changing of the climate is OUR existential threat.” | |||||
| ▸147 | July 31, 2026 | Mike Rueli | 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 | |||||
| ▸146 | July 31, 2026 | Mark Moulton, EPACANDO Board of Directors | Oppose rescission | Individual | CFR |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework CFR Climate-related financial risk — “Good investment strategy HAS to take climate disruption into account!” | |||||
| ▸145 | July 31, 2026 | Leslie Wharton | Oppose rescission | Individual | CAPFORM 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 — “essential to the free market economy” IP Investor protection / decision usefulness — “Investors need to have relevant, timely information to make their decisions” | |||||
| ▸144 | July 31, 2026 | Julie Solomon, American Nurses Association | 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 — “requires publicly traded companies to disclose their climate risks in financial filings” IP Investor protection / decision usefulness — “Not requiring this information leaves investors and the public-at-large in the dark when it comes to climate risk.” | |||||
| ▸143 | July 31, 2026 | Joy Rosenberry Chase | 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 — “Keep requiring businesses to disclose their contributions to climate change so you have the information necessary to stop the climate upheaval.” ENV Environmental impact / consequences — “France and Spain have unprecedented wildfires; half of the U.S. and Canada are suffering from wildfire smoke; most of the U.S. is in drought, as is the U.K.; storms and tornadoes are getting worse and more frequent.” | |||||
| ▸142 | July 31, 2026 | Jeri Woodward | 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 — “Our planet is currently either on fire, flooding or experiencing g droughts and other climate crises.” | |||||
| ▸141 | July 31, 2026 | Gwendolyn Frances Andary | 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 | |||||
| ▸140 | July 31, 2026 | G De Kock | Oppose rescission | Individual | AUTH CBA CMP |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework AUTH Statutory authority / major-questions (either direction) — “the rule falls well within the agency's statutory authority” CBA Cost-benefit assessment — “the benefits of standardized disclosure far outweigh the costs” CMP Standardization / comparability — “the benefits of standardized disclosure far outweigh the costs” | |||||
| ▸139 | July 31, 2026 | Dr. Lisa Barrington | Oppose rescission | Individual | ENV FRAG IP |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework ENV Environmental impact / consequences — “We the people want clean air, soil, water, and a working ozone.” FRAG Regulatory fragmentation / multi-jurisdictional consistency — “More than 41 countries, accounting for 60 percent of the world's GDP, have approved or proposed climate disclosure rules.” IP Investor protection / decision usefulness — “the millions of Americans whose financial future depends on their investments” | |||||
| ▸138 | July 31, 2026 | Diana Kekule | Oppose rescission | Individual | FRAG IP |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework FRAG Regulatory fragmentation / multi-jurisdictional consistency — “More than 40 countries—representing 60 percent of global GDP—have approved or proposed climate disclosure rules of their own.” IP Investor protection / decision usefulness — “the millions of Americans whose financial futures depend on their investments” | |||||
| ▸137 | July 31, 2026 | David Corbin, Professor Emeritus, University of Nebraska Omaha | 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 — “I am concerned about the financial impacts of extreme weather.” IP Investor protection / decision usefulness — “Companies and citizens have a right to know the financial impacts of the increasing number of weather-related incidents.” | |||||
| ▸136 | July 31, 2026 | Carolin Schellhorn | 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 — “These risks are material because natural disasters (floods, wildfires, hurricanes,....) are supercharged by global warming and can do tremendous damage to businesses large and small in all industries.” ENV Environmental impact / consequences — “natural disasters (floods, wildfires, hurricanes,....) are supercharged by global warming” IP Investor protection / decision usefulness — “Investors should be able to access information about companies' exposures to these risks and their efforts to mitigate them and adapt.” | |||||
| ▸135 | July 31, 2026 | Anonymous | 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 | |||||
| ▸134 | July 31, 2026 | Sarah Wilson, Founder and Chief Executive Officer, Minerva Analytics Ltd | Oppose rescission | Environmental / ESG advocacy org | Modify / Improve or Clarify ACCT AUTH CAPFORM CB CBA CFR CMP DEMAND FRAG INSUFF IP WHIP GOV TARGETS GHG12 FINSTMT |
Position: Oppose rescission (unanimous) · Entity: Environmental / ESG advocacy org (unanimous) Modification posture: Modify / Improve or Clarify — asks for a revised, clarified or better-designed framework Keep provisions: GOV (Governance / risk management), TARGETS (Targets / transition plan), GHG12 (Scope 1 & 2 emissions), FINSTMT (Financial-statement effects (Reg S-X Art. 14)) ACCT Stewardship / accountability — “boards that
receive consistent climate-related risk information are better placed to exercise informed
oversight of strategy, capital allocation and risk management” AUTH Statutory authority / major-questions (either direction) — “The securities statutes nevertheless give the Commission authority to specify information in registration statements and periodic
reports where the statutory standards are met” CAPFORM Market efficiency / capital formation — “it facilitates capital formation by giving
US issuers a credible, interoperable standard through which to reach global capital” CB Compliance burden — “disproportionately
burdensome or difficult to implement” CBA Cost-benefit assessment — “the analysis cannot demonstrate that the net benefits of complete rescission are positive” CFR Climate-related financial risk — “realised financial-
effect disclosures” CMP Standardization / comparability — “reduce avoidable variation in terminology, location, units and reporting period when
materially relevant information is disclosed” DEMAND Investor demand / fund reliance — “Institutional investors representing tens of trillions of dollars in assets under management have told the Commission,
in the 2022 comment record and since, that they seek this information” FRAG Regulatory fragmentation / multi-jurisdictional consistency — “IFRS S2 continues to organize climate-related financial disclosure around governance,
strategy, risk management, and metrics and targets” INSUFF Insufficient / incoherent legal basis (either direction) — “If the principal measurable benefits are avoided issuer costs while
recognised investor and information-market costs remain unquantified, the analysis cannot demonstrate
that the net benefits of complete rescission are positive” IP Investor protection / decision usefulness — “Minerva supports a disclosure regime anchored in the information a reasonable investor would consider important in making investment or voting decisions” WHIP Regulatory whiplash / reliance interests / costs already incurred — “the difference between sunk or fixed reporting-system costs and genuinely avoidable future costs” | |||||
| ▸133 | July 31, 2026 | Center for Climate and Energy Solutions (C2ES) | Oppose rescission | Environmental / ESG advocacy org | Fallback / Compromise ACCT AUTH CAPFORM CB CBA CFR CMP DEMAND FRAG INSUFF IP WHIP GOV TARGETS GHG12 FINSTMT |
Position: Oppose rescission (unanimous) · Entity: Environmental / ESG advocacy org (unanimous) Modification posture: Fallback / Compromise — primary position is clear; a second-best alternative is offered if it is rejected Keep provisions: GOV (Governance / risk management), TARGETS (Targets / transition plan), GHG12 (Scope 1 & 2 emissions), FINSTMT (Financial-statement effects (Reg S-X Art. 14)) ACCT Stewardship / accountability — “The governance, strategy, and risk management disclosure items (Items 1501–1503)” AUTH Statutory authority / major-questions (either direction) — “In C2ES's view, the Final Rules are within the Commission's statutory authority” CAPFORM Market efficiency / capital formation — “capital-
formation concerns are most acute” CB Compliance burden — “Much of the burden the Commission now cites as justification for rescission, the "difficult” CBA Cost-benefit assessment — “C2ES has previously offered practical implementation-focused alternatives, informed by company
experiences and feedback, to address the most burdensome elements of the Final Rules without
abandoning the disclosure framework” CFR Climate-related financial risk — “that may affect its strategy, operations, and financial condition” CMP Standardization / comparability — “market participants must have access to consistent, comparable, and reliable
information” DEMAND Investor demand / fund reliance — “Many investors seek this information, and many leading companies already provide at least
some form of it” FRAG Regulatory fragmentation / multi-jurisdictional consistency — “The Commission cites the EU's narrowing of the CSRD and CSDDD and the ISSB's amendments to IFRS S2” INSUFF Insufficient / incoherent legal basis (either direction) — “We disagree with the Commission's characterization of the Final Rules as a "dramatic overreach"
unsupported by any legitimate investor need” IP Investor protection / decision usefulness — “consistent, comparable, and reliable
information on climate-related risks to ensure that markets are fair, capital is efficiently allocated, and
investors are protected” WHIP Regulatory whiplash / reliance interests / costs already incurred — “itself imposes additional costs on companies and would be a poor use of the
investments already made” | |||||
| ▸132 | July 31, 2026 | Thomas P. DiNapoli, New York State Comptroller | Oppose rescission | Government / elected official | ACCT CAPFORM CBA CFR CMP INSUFF IP WHIP |
Position: Oppose rescission (unanimous) · Entity: Government / elected official (unanimous) Modification posture: No modification requested — no substantive request to change the framework ACCT Stewardship / accountability — “Climate-related disclosures help inform the Fund’s assessment of portfolio
companies’ risk management practices, capital allocation decisions, transition planning,
emissions reduction strategies, and board oversight of material climate risks” CAPFORM Market efficiency / capital formation — “thereby supporting more efficient capital
allocation and risk management” CBA Cost-benefit assessment — “This framing fails a comprehensive cost-benefit analysis” CFR Climate-related financial risk — “Physical climate risks, transition risks, technological developments,
changing market dynamics, and evolving regulatory requirements can affect corporate
earnings, asset values, capital expenditures, and long-term competitiveness” CMP Standardization / comparability — “Standardized disclosure requirements improve the quality and consistency of the data used by
investors, index providers, and asset managers” INSUFF Insufficient / incoherent legal basis (either direction) — “we reject the stated Commission policy justification for rescission, which is
heavily premised on corporate compliance cost savings” IP Investor protection / decision usefulness — “allow investors to
evaluate companies on a comparable basis” WHIP Regulatory whiplash / reliance interests / costs already incurred — “Many public companies have likely already allocated substantial capital into their planned compliance
infrastructure necessary to adhere to the existing climate disclosure framework. Abandoning
the rule now penalizes those companies that proactively planned” | |||||
| ▸131 | July 31, 2026 | Ethan Birchard, Executive Director, Friends Fiduciary Corporation | Oppose rescission | Investor / asset manager (institutional) | ACCT CB CFR CMP DEMAND FRAG IP GHG12 GOV FINSTMT TARGETS |
Position: Oppose rescission (unanimous) · Entity: Investor / asset manager (institutional) (unanimous) Modification posture: No modification requested — no substantive request to change the framework 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” CB Compliance burden — “We do not have a large budget to purchase climate related research and should not be required to
continue to rely on third-party estimates” CFR Climate-related financial risk — “The systemic risk of climate change
and the impacts we are already seeing on company operations are major concerns for our faith
community” CMP Standardization / comparability — “Institutional investors representing tens of trillions of dollars in assets have told the Commission” DEMAND Investor demand / fund reliance — “Institutional investors representing tens of trillions of dollars in assets have told the Commission,
across multiple comment cycles since 2021, that standardized, mandatory, comparable climate
disclosure is decision-useful” FRAG Regulatory fragmentation / multi-jurisdictional consistency — “The lack of a
regulatory mandate has led to inconsistent information across multiple reporting regimes” IP Investor protection / decision usefulness — “climate-related financial information is critical to our fundamental research,
valuation and risk management processes that inform our investment decision-making” | |||||
| ▸130 | July 31, 2026 | Dalia Thornton, Director, Department of Research and Collective Bargaining Services, American Federation of State, County and Municipal Employees (AFSCME) | Oppose rescission | Business trade association / advocacy org | AUTH CAPFORM CB CBA CFR CMP DEMAND FRAG IP |
Position: Oppose rescission (unanimous) · Entity: Business trade association / advocacy org (unanimous) Modification posture: No modification requested — no substantive request to change the framework AUTH Statutory authority / major-questions (either direction) — “the SEC is taking the position that the 2024 Rule "should be rescinded because they
exceed the statutory limits on the Commission's disclosure authority." We disagree” CAPFORM Market efficiency / capital formation — “protecting market integrity are
essential to maintaining efficient, transparent capital markets that
promote capital formation” CB Compliance burden — “providing minimal compliance cost savings for issuers that are already required to make climate-related disclosures elsewhere” CBA Cost-benefit assessment — “Rescinding required climate disclosures, as the
Proposed Rule would do, will harm investors while providing minimal compliance cost
savings for issuers” CFR Climate-related financial risk — “Climate change presents material financial risks and
opportunities that clearly affect company performance and impact long-term returns” CMP Standardization / comparability — “Investors need comparable and consistent information, and
issuers need definitive guidance and a level playing field” DEMAND Investor demand / fund reliance — “an analysis of comments from 320 institutional investors with more than $50 trillion in
assets finding 97% of the comments supported required climate risk disclosures” FRAG Regulatory fragmentation / multi-jurisdictional consistency — “companies operating in the European
Union must adhere to the Corporate Sustainability Reporting Directive” IP Investor protection / decision usefulness — “Investors require a wide range of climate-related
information designed to understand the long-term performance and risk management strategies of
public-reporting companies” | |||||
| ▸129 | July 31, 2026 | Jen Sisson, CEO, International Corporate Governance Network (ICGN) | Oppose rescission | Investor / asset manager (institutional) | Fallback / Compromise ACCT CAPFORM CB CBA CFR CMP DEMAND FRAG INSUFF IP FINSTMT GOV |
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: FINSTMT (Financial-statement effects (Reg S-X Art. 14)), GOV (Governance / risk management) ACCT Stewardship / accountability — “boards are
ultimately responsible for overseeing the company's risk management, strategy and long-
term interests” CAPFORM Market efficiency / capital formation — “protecting investors, maintaining
fair, orderly and efficient markets, and facilitating capital formation” CB Compliance burden — “A reduction in direct
issuer compliance costs is not a genuine saving if those costs are merely transferred to
investors and multiplied across the market” CBA Cost-benefit assessment — “The costs to investors outweigh the costs to companies” CFR Climate-related financial risk — “Climate-related risks can affect companies through physical damage, business disruption,
changing regulation, transition costs, energy prices, supply-chain exposure, insurance
availability, financing costs, asset impairment and changing customer demand” CMP Standardization / comparability — “Without a common framework, companies may use
different definitions, methodologies, reporting locations and levels of assurance, making the
information difficult to compare or verify” DEMAND Investor demand / fund reliance — “Rescinding the Final Rules will not eliminate the demand for climate-related information.
Investors will continue to request it” FRAG Regulatory fragmentation / multi-jurisdictional consistency — “Rescission may therefore increase complexity by leaving companies to reconcile multiple
regimes without a federal baseline” INSUFF Insufficient / incoherent legal basis (either direction) — “Rescinding the Final Rules entirely, rather than refining them further, if necessary, would disregard this extensive
rulemaking process and create unnecessary regulatory uncertainty” IP Investor protection / decision usefulness — “investors need company-specific disclosure based on materiality” | |||||
| ▸126 | July 31, 2026 | Kevin Thomas, CEO, SHARE (Shareholder Association for Research & Education) | Oppose rescission | Environmental / ESG advocacy org | AUTH CAPFORM CB CBA CMP DEMAND FRAG IP GHG12 GOV TARGETS FINSTMT |
Position: Oppose rescission (unanimous) · Entity: Environmental / ESG advocacy org (unanimous) Modification posture: No modification requested — no substantive request to change the framework Keep provisions: GHG12 (Scope 1 & 2 emissions), GOV (Governance / risk management), TARGETS (Targets / transition plan), FINSTMT (Financial-statement effects (Reg S-X Art. 14)) AUTH Statutory authority / major-questions (either direction) — “Issuing material climate-
related disclosure rules is fully within the frame of federal securities laws and statutory” CAPFORM Market efficiency / capital formation — “contravene the Commission's own mandate to protect investors, maintain fair and efficient markets, and facilitate capital formation” CB Compliance burden — “A voluntary, fragmented disclosure regime actually creates more work for issuers than a standardized” CBA Cost-benefit assessment — “corporate issuers are
spending $533,000 annually on climate-related disclosure, while institutional investors are
spending an average of $1,372,000 annually to collect, analyze, and report climate data” CMP Standardization / comparability — “The 2024 rules set a common baseline that allows investors to compare material risk exposures across
companies and sectors on a consistent basis” DEMAND Investor demand / fund reliance — “it catalogued 2021 comment letters from asset managers and industry bodies
collectively representing well over $100 trillion in assets under management or advisement
in support of mandatory climate disclosure” FRAG Regulatory fragmentation / multi-jurisdictional consistency — “makes US firm data interoperable with global markets” IP Investor protection / decision usefulness — “Investors use material climate-related information in investment decisions” | |||||
| ▸125 | July 31, 2026 | Professors Jill E. Fisch, George S. Georgiev, Donna M. Nagy and Cynthia A. Williams | Oppose rescission | Academic researcher | AUTH CFR CMP IP |
Position: Oppose rescission (unanimous) · Entity: Academic researcher (unanimous) Modification posture: No modification requested — no substantive request to change the framework AUTH Statutory authority / major-questions (either direction) — “the SEC's 2024 climate-related disclosure rules were properly promulgated in
reliance on the Commission's statutory authority, and, thus, the proposed rescission of the rules
on the asserted basis of a lack of statutory authority is, in our view, incorrect” CFR Climate-related financial risk — “Climate-
related risks continue to affect issuers, investors, and capital markets” CMP Standardization / comparability — “Mainstream, reasonable
investors continue to need consistent, comparable, and reliable disclosure” IP Investor protection / decision usefulness — “to ensure that public company disclosure provides
investors with information material to investment and voting decisions” | |||||
| ▾ July 30, 2026 8 letters | |||||
| ▸155 | July 30, 2026 | 2,245 Comments on behalf of Sierra Club Supporters | Oppose rescission | Environmental / ESG advocacy org | ACCT CAPFORM CFR CMP ENV IP |
Position: Oppose rescission (unanimous) · Entity: Environmental / ESG advocacy org (unanimous) Modification posture: No modification requested — no substantive request to change the framework ACCT Stewardship / accountability — “Companies that
pollute the most need to be held accountable for their pollution” CAPFORM Market efficiency / capital formation — “The SEC's core mission is to protect investors, maintain fair and orderly markets, and facilitate
capital formation.” CFR Climate-related financial risk — “Climate-related financial risks are not hypothetical. They are already a]ecting corporate
operations, infrastructure, supply chains, insurance markets, and asset values across the
economy.” CMP Standardization / comparability — “A consistent disclosure framework simply helps ensure that this information is
reliable, comparable, and available to all investors” ENV Environmental impact / consequences — “Excessive pollution also brings
about poor air quality, which has negative consequences for our health.” IP Investor protection / decision usefulness — “Investors cannot make
informed decisions if material risks remain hidden or are disclosed inconsistently.” | |||||
| ▸124 | July 30, 2026 | Anders Schelde, Chief Investment Officer, AkademikerPension | Oppose rescission | Investor / asset manager (institutional) | ACCT CAPFORM CFR CMP 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 — “Standardised disclosures provide a common factual basis for dialogue with companies, informed voting decisions and accountability over time” CAPFORM Market efficiency / capital formation — “Corporate disclosure plays a fundamental role in protecting investors and” CFR Climate-related financial risk — “these risks are financially material because they influence companies' resilience, future cash flows and long -term value creation” CMP Standardization / comparability — “we believe investors continue to benefit from a consistent framework for climate -related disclosures that support transparency, comparability and informed decision -making” IP Investor protection / decision usefulness — “own informed judgments based on transparent, reliable and comparable” | |||||
| ▸121 | July 30, 2026 | Steven Rothstein, Chief Program Officer; Thomas L. Riesenberg, Senior Advisor; Jim Coburn, Senior Manager, Ceres | Oppose rescission | Environmental / ESG advocacy org | AUTH CAPFORM CBA CFR CMP DEMAND FRAG INSUFF IP PP |
Position: Oppose rescission (unanimous) · Entity: Environmental / ESG advocacy org (unanimous) Modification posture: No modification requested — no substantive request to change the framework AUTH Statutory authority / major-questions (either direction) — “The Commission's self-imposed statutory hamstringing lacks merit.” CAPFORM Market efficiency / capital formation — “these other disclosure mandates undermine the cost-benefit and capital formation arguments made by the SEC” CBA Cost-benefit assessment — “the economic analysis vastly overstates the cost of compliance and understates the benefits” CFR Climate-related financial risk — “$2.9 billion in losses related to extreme weather were recorded by 3,890 companies reporting to CDP in 2025” CMP Standardization / comparability — “need to improve the consistency, comparability, and reliability of climate-related disclosures for investors” DEMAND Investor demand / fund reliance — “investor demand and need for comparable and decision-useful climate information was emphatically established during the 2022-2024 rulemaking” FRAG Regulatory fragmentation / multi-jurisdictional consistency — “the EU's Corporate Sustainability Reporting Directive (CSRD) covers around 1,200 non-EU companies” INSUFF Insufficient / incoherent legal basis (either direction) — “rescission of the Final Rules would be arbitrary and capricious” IP Investor protection / decision usefulness — “Investors need to understand the magnitude of company-specific risk exposures to prioritize engagements and inform proxy voting.” PP Political pressure / regulatory capture — “the Rescission Proposal was issued by a Commission with only three Commissioners from one party” | |||||
| ▸120 | July 30, 2026 | Rev. Bryan Pham, S.J., Chair, Jesuit Committee on Investment Responsibility | Oppose rescission | Investor / asset manager (institutional) | ACCT AUTH CAPFORM CBA 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 — “Collectively, we engage as shareholders or bondholders 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” CAPFORM Market efficiency / capital formation — “This supports more informed investment, productive shareholder engagement, and efficient capital markets.” CBA Cost-benefit assessment — “It is no longer reasonable for the Commission to ask us to continue to bear these costs and staff resources to engage company-by-company” CFR Climate-related financial risk — “the risks to company operations posed by climate-related issues” CMP Standardization / comparability — “allowing investors to compare companies using common metrics” DEMAND Investor demand / fund reliance — “an overwhelming majority of institutional investors made clear that the Rule was needed” FRAG Regulatory fragmentation / multi-jurisdictional consistency — “mandatory disclosures for companies doing business in California and the E.U., as well as voluntary sets” IP Investor protection / decision usefulness — “Climate-related disclosures are critical for our effective investment analysis and decision-making.” | |||||
| ▸119 | July 30, 2026 | Matt Chambers | Oppose rescission | Individual | AUTH CFR ENV IP |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework AUTH Statutory authority / major-questions (either direction) — “I disagree with the premise that the SEC does not have authority to adopt the rule” CFR Climate-related financial risk — “Climate change will greatly affect individual companies, and their securities.” ENV Environmental impact / consequences — “The path we are on is likely to make the Earth uninhabitable for much, if not all, of the human race.” IP Investor protection / decision usefulness — “climate change disclosure is important and clearly material financial disclosure” | |||||
| ▸118 | July 30, 2026 | Leon Kamhi, Executive Vice President, Head of Responsibility and EOS, Federated Hermes Limited | Oppose rescission | Investor / asset manager (institutional) | Modify / Improve or Clarify CAPFORM CB CFR CMP DEMAND IP REDUN |
Position: Oppose rescission (majority) · Entity: Investor / asset manager (institutional) (unanimous) Modification posture: Modify / Improve or Clarify — asks for a revised, clarified or better-designed framework CAPFORM Market efficiency / capital formation — “increased compliance costs and market inefficiencies” CB Compliance burden — “Streamlining certain requirements may initially reduce the disclosure burden for companies” CFR Climate-related financial risk — “connectivity between different issues and various dimensions of company financial performance over time” CMP Standardization / comparability — “disclosure requirements for all companies to promote consistency and comparability, which would complement more flexible principles-based requirements.” DEMAND Investor demand / fund reliance — “the record has established strong investor demand for relevant, material, consistent and comparable climate-related data and information” IP Investor protection / decision usefulness — “essential for investors to assess performance, understand how management commitments affect financial results, and make informed decisions” REDUN Redundant — existing rules, materiality regime, or voluntary reporting already suffice — “We agree with the Commission that there are opportunities to eliminate redundancies across disclosure requirements” | |||||
| ▸117 | July 30, 2026 | Jeff Mahoney, General Counsel, Council of Institutional Investors | Oppose rescission | Investor / asset manager (institutional) | Modify / Improve or Clarify ACCT AUTH CAPFORM CB CBA CFR CMP DEMAND FRAG IP GHG12 GHG3 GOV TARGETS FINSTMT |
Position: Oppose rescission (unanimous) · Entity: Investor / asset manager (institutional) (unanimous) Modification posture: Modify / Improve or Clarify — asks for a revised, clarified or better-designed framework Keep provisions: GHG12 (Scope 1 & 2 emissions), GHG3 (Scope 3 emissions), GOV (Governance / risk management), TARGETS (Targets / transition plan), FINSTMT (Financial-statement effects (Reg S-X Art. 14)) ACCT Stewardship / accountability — “The board should disclose to shareowners, at least annually, sufficient information to enable them to assess whether the board is carrying out its oversight responsibilities effectively.” AUTH Statutory authority / major-questions (either direction) — “There is no doctrine in the securities laws generally, or with respect to materiality specifically, that renders that kind of disclosure mandate beyond the scope of the SEC’s mandate.” CAPFORM Market efficiency / capital formation — “The efficiency of global markets—and the well-being of the investors who entrust their financial present and future to those markets—depends, in significant part, on the quality, comparability and reliability of the information provided by audited financial statements and disclosures.” CB Compliance burden — “remain concerned about the challenges that companies will face in calculating and reporting Scope 3 emissions” CBA Cost-benefit assessment — “the anticipated benefit to investors of having more complete emission disclosures by mandating Scope 3 disclosures exceeds the cost of collecting and reporting the information” CFR Climate-related financial risk — “CII generally believes that climate change is a critical systemic risk that long-term institutional investors must address as part of their fiduciary duty.” CMP Standardization / comparability — “it may improve the consistency, comparability and reliability of the proposed disclosures” DEMAND Investor demand / fund reliance — “Since 2010, investor demand for, and company disclosure of information about, climate change risks, impacts, and opportunities has grown dramatically.” FRAG Regulatory fragmentation / multi-jurisdictional consistency — “a registrant that is a foreign private issuer and subject to the climate-related disclosure of an alternative reporting regime, to satisfy its disclosure obligations under the Proposed Rule by complying with the reporting requirements of the alternative reporting regime” IP Investor protection / decision usefulness — “information reported in the financial statements that would be relevant to investors when making investment or voting decisions” | |||||
| ▸116 | July 30, 2026 | Chad M. Horning, Chief Strategy Officer and Chief Investment Officer, Everence Financial; President, Praxis Investment Management | Oppose rescission | Investor / asset manager (institutional) | ACCT AUTH CFR CMP DEMAND 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 also practice corporate engagement, using the rights and privileges of our ownership in securities to promote corporate change.” AUTH Statutory authority / major-questions (either direction) — “we respectfully disagree with this Commission's unprecedented argument that it lacks the authority to do what Congress charged it to do” CFR Climate-related financial risk — “assess portfolio-wide climate-related impacts to investment returns” CMP Standardization / comparability — “Praxis believes that both investors and companies would benefit from the standardized, comparable, mandatory disclosures that the structure of the 2024 Rules provide.” DEMAND Investor demand / fund reliance — “an overwhelming majority of institutional investors made clear that the Rule was needed” IP Investor protection / decision usefulness — “Climate-related disclosures are critical for our effective investment analysis and decision-making.” | |||||
| ▾ July 29, 2026 3 letters | |||||
| ▸122 | July 29, 2026 | Vancity Investment Management | Oppose rescission | Investor / asset manager (institutional) | Fallback / Compromise ACCT AUTH CAPFORM CB CFR CMP FRAG IP GHG12 GOV FINSTMT |
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)) ACCT Stewardship / accountability — “We engage companies on climate risk exposure, mitigation strategies, credible transition planning, and recognized sustainability reporting practices.” AUTH Statutory authority / major-questions (either direction) — “fall comfortably within the Commission's traditional, well-established disclosure authority” CAPFORM Market efficiency / capital formation — “supports more effective capital allocation and long-term risks consideration for investors” CB Compliance burden — “the Rules are not unduly burdensome to companies, as they only require disclosure of information that applies to a particular company's operations” CFR Climate-related financial risk — “Climate change presents financially material physical and transition risks across sectors.” CMP Standardization / comparability — “reduce the availability and comparability of information investors need to assess the long-term risks” FRAG Regulatory fragmentation / multi-jurisdictional consistency — “mandatory disclosures for companies doing business in California and the European Union” IP Investor protection / decision usefulness — “Material climate information is an input into assessing business resilience, cost of capital, regulatory risk” | |||||
| ▸115 | July 29, 2026 | James McRitchie, Shareholder Advocate, CorpGov.net | Oppose rescission | Individual | Fallback / compromise AUTH CAPFORM CBA CFR CMP DEMAND IP GOV TARGETS FINSTMT |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: Fallback / compromise — Keep provisions: GOV (Governance / risk management), TARGETS (Targets / transition plan), FINSTMT (Financial-statement effects (Reg S-X Art. 14)) AUTH Statutory authority / major-questions (either direction) — “I agree fully with the July 28, 2026, comment letter submitted by Sanford Lewis and Khadija Foda. Their analysis of the Commission's authority” CAPFORM Market efficiency / capital formation — “It's basic portfolio economics.” CBA Cost-benefit assessment — “The Commission's Own Economic Analysis Undercuts the Case for Rescission” CFR Climate-related financial risk — “the same physical or transition risks affect many others” CMP Standardization / comparability — “Diversified Investors Need Comparable Information Across Portfolios” DEMAND Investor demand / fund reliance — “I agree fully with the July 28, 2026, comment letter submitted by Sanford Lewis and Khadija Foda. Their analysis of the Commission's authority, the depth of investor demand” IP Investor protection / decision usefulness — “reliable, comparable, decision-useful information” | |||||
| ▸109 | July 29, 2026 | Cynthia Hanawalt, Director, Sabin Center for Climate Change Law, Columbia Law School | Oppose rescission | Academic researcher | AUTH CAPFORM CB CBA CFR CMP DEMAND FRAG INSUFF IP WHIP |
Position: Oppose rescission (unanimous) · Entity: Academic researcher (unanimous) Modification posture: No modification requested — no substantive request to change the framework AUTH Statutory authority / major-questions (either direction) — “The Commission Has the Authority to Require Climate Financial Risk Disclosure” CAPFORM Market efficiency / capital formation — “correlated actionable climate disclosure with a lower cost of capital” CB Compliance burden — “the incremental cost of compliance with the Final Rule is likely modest for the many registrants” CBA Cost-benefit assessment — “Cost-Benefit Economic Analysis Favors the Final Rule” CFR Climate-related financial risk — “the financial materiality of climate-related risks” CMP Standardization / comparability — “standardized and comparative climate-risk reporting” DEMAND Investor demand / fund reliance — “Significant Investor Demand Is Probative of Materiality” FRAG Regulatory fragmentation / multi-jurisdictional consistency — “Many U.S. registrants will already be required to produce climate data under California law and under the European Union's Corporate Sustainability Reporting Directive” INSUFF Insufficient / incoherent legal basis (either direction) — “An agency may change course, but not without reasonable explanation.” IP Investor protection / decision usefulness — “Climate Information Is Material Under the Governing Standard” WHIP Regulatory whiplash / reliance interests / costs already incurred — “to Account for Reliance Interests the Final Rule Engendered” | |||||
| ▾ July 28, 2026 16 letters | |||||
| ▸114 | July 28, 2026 | Marcie Frost, Chief Executive Officer, California Public Employees' Retirement System (CalPERS) | Oppose rescission | Investor / asset manager (institutional) | ACCT CAPFORM CBA 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 ACCT Stewardship / accountability — “act as an informed steward consistent with our fiduciary duty” CAPFORM Market efficiency / capital formation — “better serve the efficiency of U.S. capital markets” CBA Cost-benefit assessment — “it would fundamentally alter the cost-benefit equation by shifting the financial burden directly onto investors” CFR Climate-related financial risk — “climate-related risks are financially material risks” CMP Standardization / comparability — “compare material risk exposures across companies and sectors on a consistent basis” FRAG Regulatory fragmentation / multi-jurisdictional consistency — “the absence of a unified federal standard leaves companies and investors to navigate an emerging patchwork of state-level disclosure requirements” IP Investor protection / decision usefulness — “essential for reasonable investors to make informed capital allocation decisions” | |||||
| ▸113 | July 28, 2026 | Brooke E. Lierman, Comptroller of Maryland | Oppose rescission | Government / elected official | CAPFORM CBA CFR CMP IP |
Position: Oppose rescission (unanimous) · Entity: Government / elected official (unanimous) Modification posture: No modification requested — no substantive request to change the framework CAPFORM Market efficiency / capital formation — “capital formation is strengthened when investors have confidence that public companies are providing consistent, material, and comparable information” CBA Cost-benefit assessment — “focus heavily on compliance costs to registrants while giving insufficient weight to the costs investors bear” CFR Climate-related financial risk — “Climate-Related Risk Is Financial Risk” CMP Standardization / comparability — “consistent information to evaluate how companies identify, manage, and disclose material climate” IP Investor protection / decision usefulness — “investors should receive material information needed to make informed investment decisions” | |||||
| ▸112 | July 28, 2026 | Mark D. Levine, Comptroller, City of New York | Oppose rescission | Government / elected official | ACCT AUTH CAPFORM CFR CMP DEMAND IP GOV TARGETS |
Position: Oppose rescission (unanimous) · Entity: Government / elected official (unanimous) Modification posture: No modification requested — no substantive request to change the framework Keep provisions: GOV (Governance / risk management), TARGETS (Targets / transition plan) ACCT Stewardship / accountability — “Boards and executives must identify, measure, monitor, and manage material risks.” AUTH Statutory authority / major-questions (either direction) — “is fully within the SEC's authority and that rescinding it will impair market efficiency, raise costs” CAPFORM Market efficiency / capital formation — “impair market efficiency” CFR Climate-related financial risk — “climate-related risks are not theoretical or remote” CMP Standardization / comparability — “reliable, consistent, decision-useful disclosures” DEMAND Investor demand / fund reliance — “Investors, including pension funds, asset managers, insurers, and retail investors, overwhelmingly stated that they need standardized climate related information” IP Investor protection / decision usefulness — “our fiduciary duty demands full consideration of material climate-related financial risks” | |||||
| ▸111 | July 28, 2026 | Laura Peterson and Kathy Mulvey, Union of Concerned Scientists | Oppose rescission | Environmental / ESG advocacy org | ACCT CBA CFR CMP DEMAND ENV FRAG IP PP |
Position: Oppose rescission (unanimous) · Entity: Environmental / ESG advocacy org (unanimous) Modification posture: No modification requested — no substantive request to change the framework ACCT Stewardship / accountability — “insulating high-emitting industries from accountability” CBA Cost-benefit assessment — “faulty cost-benefit analysis” CFR Climate-related financial risk — “the serious financial risk posed by climate change demands action” CMP Standardization / comparability — “comparable, consistent, and decision-useful information investors need” DEMAND Investor demand / fund reliance — “vast majority of the more than 20,000 commenters on the 2024 rule said requiring” ENV Environmental impact / consequences — “the past 12 years have been the warmest on record” FRAG Regulatory fragmentation / multi-jurisdictional consistency — “More than 20 jurisdictions accounting for around 75% of global market capitalization outside the US have or are in the process of adopting similar standards” IP Investor protection / decision usefulness — “providing investors with information necessary for managing the costs of climate change” PP Political pressure / regulatory capture — “The political context of the Commission's proposal is impossible to ignore. The oil and gas” | |||||
| ▸110 | July 28, 2026 | Gabriel Thoumi, CFA, FRM, President and Chief Executive Officer, Responsible Alpha, Inc. | Oppose rescission | Environmental / ESG advocacy org | ACCT AUTH CAPFORM CFR CMP DEMAND IP |
Position: Oppose rescission (unanimous) · Entity: Environmental / ESG advocacy org (unanimous) Modification posture: No modification requested — no substantive request to change the framework ACCT Stewardship / accountability — “Weakening Corporate Governance and Risk Oversight” AUTH Statutory authority / major-questions (either direction) — “A Pathway to Stripping Investor Protections” CAPFORM Market efficiency / capital formation — “creating systemic market inefficiencies” CFR Climate-related financial risk — “Both investors and companies acknowledge that climate change has a material impact on business.” 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” IP Investor protection / decision usefulness — “Climate Risk Data is Material to Investors” | |||||
| ▸106 | July 28, 2026 | Stephanie Crowley | Oppose rescission | Individual | AUTH CAPFORM CBA CFR DEMAND ENV FRAG IP |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework AUTH Statutory authority / major-questions (either direction) — “The SEC has statutory authority to require companies to disclose information that is material to investors.” CAPFORM Market efficiency / capital formation — “at the expense of economic stability” CBA Cost-benefit assessment — “who should bear the financial burden anyway? The companies who are making a profit, or the people who increasingly suffer the effects of climate change?” CFR Climate-related financial risk — “Left unchecked, climate change is likely to cause trillions of dollars of economic damages in the United States and globally.” DEMAND Investor demand / fund reliance — “Investors overwhelmingly support collection and disclosure of information on climate-related financial risk.” ENV Environmental impact / consequences — “it's a matter of life and death (witness the wildfires in France and Spain)” FRAG Regulatory fragmentation / multi-jurisdictional consistency — “these companies are already required to disclose this information in dozens of jurisdictions around the world” IP Investor protection / decision usefulness — “investors, regulators, and the public are less able informed decisions” | |||||
| ▸105 | July 28, 2026 | Sanford Lewis and Khadija Foda, Sanford Lewis & Associates | Oppose rescission | Legal practitioner | ACCT AUTH CFR CMP DEMAND INSUFF IP |
Position: Oppose rescission (unanimous) · Entity: Legal practitioner (unanimous) Modification posture: No modification requested — no substantive request to change the framework ACCT Stewardship / accountability — “exercise informed oversight of the companies they own” AUTH Statutory authority / major-questions (either direction) — “Materiality Is Not a Ceiling on the Commission's Disclosure Authority” CFR Climate-related financial risk — “third-party climate analytics to assess threats to portfolio company earnings, asset valuations, and exit outcomes” CMP Standardization / comparability — “improving the quality, comparability, and consistency of disclosure concerning material climate-related risks” DEMAND Investor demand / fund reliance — “Ceres analyzed the comment letters of 320 institutional investors, collectively owning or managing more than $50 trillion in assets, and found near-unanimous support” INSUFF Insufficient / incoherent legal basis (either direction) — “The Release Can Dismiss That Record Only by Mischaracterizing It” IP Investor protection / decision usefulness — “Investors cannot price risk, allocate capital, or exercise informed oversight of the companies they own without meaningful disclosure” | |||||
| ▸104 | July 28, 2026 | Marya Grambs | 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 | |||||
| ▸103 | July 28, 2026 | Mary Minette, Senior Director of Shareholder Advocacy, Mercy Investment Services | Oppose rescission | Investor / asset manager (institutional) | ACCT CAPFORM CBA CFR CMP 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 — “environmental, social, and governance issues not as a mater of advocacy alone” CAPFORM Market efficiency / capital formation — “the stability of the markets we depend on” CBA Cost-benefit assessment — “We currently spend nearly $160,000 annually” CFR Climate-related financial risk — “Climate risk is financial risk.” CMP Standardization / comparability — “those assessments is inconsistent, incomplete” IP Investor protection / decision usefulness — “these factors materially affect the long-term value of our holdings and the stability of the markets we depend on” | |||||
| ▸102 | July 28, 2026 | Jeffrey S. Davis, Executive Director, Seattle City Employees' Retirement System (SCERS) | Oppose rescission | Investor / asset manager (institutional) | CAPFORM 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 — “reduce market efficiency, erode capital allocation decisions” CFR Climate-related financial risk — “climate change poses a systemic risk to the investment portfolio” CMP Standardization / comparability — “obtain comparable, consistent, and standardized disclosures of material, climate-related financial risks” DEMAND Investor demand / fund reliance — “there was strong investor support for climate risk disclosure rules” FRAG Regulatory fragmentation / multi-jurisdictional consistency — “additional costs to obtain, estimate, and reconcile fragmented information from voluntary reports, third-party providers, and multiple regulatory regimes” INSUFF Insufficient / incoherent legal basis (either direction) — “SCERS disputes the proposal's assertion that the Final Rules are” IP Investor protection / decision usefulness — “block fair investor access to quality data” | |||||
| ▸101 | July 28, 2026 | Janet Ranganathan, Managing Director and Executive Vice President for Strategy, Learning and Results, World Resources Institute | Oppose rescission | Environmental / ESG advocacy org | CAPFORM CB CBA CFR DEMAND FRAG INSUFF IP |
Position: Oppose rescission (unanimous) · Entity: Environmental / ESG advocacy org (unanimous) Modification posture: No modification requested — no substantive request to change the framework CAPFORM Market efficiency / capital formation — “making capital allocation less efficient market-wide” CB Compliance burden — “Rescission will not meaningfully reduce compliance costs.” CBA Cost-benefit assessment — “Whatever costs remain would be dwarfed by what investors stand to lose from undisclosed, unmanaged climate risk.” CFR Climate-related financial risk — “the impacts of extreme weather or the costs of the transition away from fossil fuels” DEMAND Investor demand / fund reliance — “Investors themselves demanded this rule.” FRAG Regulatory fragmentation / multi-jurisdictional consistency — “a patchwork of state and international disclosure requirements” INSUFF Insufficient / incoherent legal basis (either direction) — “The estimation-uncertainty rationale does not hold up.” IP Investor protection / decision usefulness — “investors lose access to financially material information” | |||||
| ▸100 | July 28, 2026 | David Sanders | Oppose rescission | Individual | ENV PP |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework ENV Environmental impact / consequences — “grave injustice to our children and grandchildren, and to our shared planet” PP Political pressure / regulatory capture — “I oppose any changes to the Climate Disclosure Rule to benefit Big Oil.” | |||||
| ▸99 | July 28, 2026 | Darlene Grossman | 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 — “protecting our planet, our investments, and future generations” IP Investor protection / decision usefulness — “protecting our planet, our investments, and future generations” | |||||
| ▸98 | July 28, 2026 | Charlotta Dawidowski Sydstrand, Head of Sustainability, AP7 | Oppose rescission | Investor / asset manager (institutional) | ACCT CAPFORM CFR CMP FRAG IP GHG12 GHG3 GOV TARGETS |
Position: Oppose rescission (unanimous) · Entity: Investor / asset manager (institutional) (unanimous) Modification posture: No modification requested — no substantive request to change the framework Keep provisions: GHG12 (Scope 1 & 2 emissions), GHG3 (Scope 3 emissions), GOV (Governance / risk management), TARGETS (Targets / transition plan) ACCT Stewardship / accountability — “We use it for security selection, inclusion and exclusion decisions across all equity mandates, monitoring corporate progress in the low-carbon transition, proxy voting” CAPFORM Market efficiency / capital formation — “impairing investors' ability to allocate capital efficiently” CFR Climate-related financial risk — “Climate change presents material financial risks and opportunities that affect company performance and long-term returns.” CMP Standardization / comparability — “reduce access to comparable, consistent, decision-useful information on material climate-related financial risks” FRAG Regulatory fragmentation / multi-jurisdictional consistency — “climate-related disclosures from U.S. companies are often less complete and comparable than disclosures from peers in other jurisdictions” IP Investor protection / decision usefulness — “we rely on high-quality corporate disclosures to assess risk, allocate capital, and fulfil our responsibilities to pension savers” | |||||
| ▸97 | July 28, 2026 | Brian Minns, Senior Managing Director, Investment Risk & Responsible Investing, University Pension Plan Ontario | Oppose rescission | Investor / asset manager (institutional) | ACCT CAPFORM CFR CMP FRAG IP GOV TARGETS |
Position: Oppose rescission (unanimous) · Entity: Investor / asset manager (institutional) (unanimous) Modification posture: No modification requested — no substantive request to change the framework Keep provisions: GOV (Governance / risk management), TARGETS (Targets / transition plan) ACCT Stewardship / accountability — “make informed capital allocation and stewardship decisions” CAPFORM Market efficiency / capital formation — “strengthen company-level transparency, effective risk oversight and efficient functioning of financial systems” CFR Climate-related financial risk — “Climate-related risks and opportunities affect company cash flows, access to finance, cost of capital, asset values, and business resilience.” CMP Standardization / comparability — “Investors rely on consistent and comparable disclosure of financially material information” FRAG Regulatory fragmentation / multi-jurisdictional consistency — “UPP supports disclosure frameworks aligned with the IFRS Foundation's International Sustainability Standards Board (ISSB) standards, including IFRS S1 and IFRS S2.” IP Investor protection / decision usefulness — “comprehensive evaluation of material climate-related risks in the investment process” | |||||
| ▸96 | July 28, 2026 | Alison Monroe | 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 risk is financial risk” ENV Environmental impact / consequences — “It's time to be frank about what fossil fuels are doing to our planet.” IP Investor protection / decision usefulness — “forcing them to provide investors with detailed information about the climate and environmental impact of their businesses” | |||||
| ▾ July 27, 2026 5 letters | |||||
| ▸108 | July 27, 2026 | Maria C. Coyne, President and Chief Executive Officer, United Church of Christ Cornerstone Fund, Inc. | Oppose rescission | Investor / asset manager (institutional) | ACCT CAPFORM CFR CMP ENV 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 — “faithful stewardship requires transparency, accountability, and informed decision-making” CAPFORM Market efficiency / capital formation — “promote efficient capital allocation, and strengthen confidence in U.S. capital markets” CFR Climate-related financial risk — “climate-related risks increasingly affect financial performance and long-term organizational resilience” CMP Standardization / comparability — “consistent and comparable framework for evaluating material climate-related risks” ENV Environmental impact / consequences — “Our work is grounded in a commitment to creation care, ecological justice, and faithful stewardship.” IP Investor protection / decision usefulness — “Access to that information is essential for investors seeking to align their investments with both their financial objectives and their values.” | |||||
| ▸107 | July 27, 2026 | Ann Scholz, SSND, PhD, Director of Corporate Social Responsibility, SSND Collective Investment Fund | Oppose rescission | Investor / asset manager (institutional) | ACCT AUTH CAPFORM CBA CFR CMP DEMAND ENV 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 ACCT Stewardship / accountability — “we file proposals asking the boards of directors for specific information” AUTH Statutory authority / major-questions (either direction) — “this Commission's unprecedented and illogical argument that it somehow lacks the authority to do what Congress charged it to do” CAPFORM Market efficiency / capital formation — “the inefficient set of investor resources dedicated to climate-related financial risk management” CBA Cost-benefit assessment — “Rescinding the Rule leaves the burden on the wrong party.” CFR Climate-related financial risk — “assess portfolio-wide climate-related impacts to investment returns” CMP Standardization / comparability — “comparable, consistent, and reliable information from issuers” DEMAND Investor demand / fund reliance — “an overwhelming majority of institutional investors made clear that the Rule was needed” ENV Environmental impact / consequences — “protect the human family and Earth our common home” FRAG Regulatory fragmentation / multi-jurisdictional consistency — “mandatory disclosures for companies doing business in California and the E.U.” INSUFF Insufficient / incoherent legal basis (either direction) — “unprecedented and illogical argument” IP Investor protection / decision usefulness — “Climate-related disclosures are critical for effective investment analysis and decision-making” | |||||
| ▸92 | July 27, 2026 | Patrice Kopistansky | Oppose rescission | Individual | AUTH CBA CFR CMP DEMAND ENV FRAG INSUFF IP |
Position: Oppose rescission (unanimous) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework AUTH Statutory authority / major-questions (either direction) — “the SEC has statutory authority to require companies to disclose information that is material to investors” CBA Cost-benefit assessment — “companies are already required to disclose this information in dozens of jurisdictions around the world, negating the SEC's argument that compliance would be excessively costly” CFR Climate-related financial risk — “Studies indicate that, left unchecked, climate change is likely to cause trillions of dollars of economic damages in the United States and globally” CMP Standardization / comparability — “It is an unsupportable, greed-driven, fact-free proposal to even think about rescinding standardized climate-related disclosure requirements for public companies” DEMAND Investor demand / fund reliance — “Previous public comments on this rule show that investors overwhelmingly support collection and disclosure of information on climate-related financial risk” ENV Environmental impact / consequences — “We have corporations making record profits at the expense of the environment and the health of the American public” FRAG Regulatory fragmentation / multi-jurisdictional consistency — “companies are already required to disclose this information in dozens of jurisdictions around the world” INSUFF Insufficient / incoherent legal basis (either direction) — “It is an unsupportable, greed-driven, fact-free proposal to even think about rescinding standardized climate-related disclosure requirements for public companies” IP Investor protection / decision usefulness — “Such disclosures provide vital information that is necessary for investors, regulators, and the public to make informed decisions in a world increasingly threatened by climate change impacts” | |||||
| ▸91 | July 27, 2026 | Kevin R. Douglas, Associate Professor of Law, Michigan State University | Support rescission | Academic researcher | IMMAT |
Position: Support rescission (unanimous) · Entity: Academic researcher (unanimous) Modification posture: No modification requested — no substantive request to change the framework IMMAT Immaterial / not decision-useful — “risks producing large volumes of speculative, inconsistent, and ultimately arbitrary information” | |||||
| ▸90 | July 27, 2026 | David S. Addington, Executive Vice President and General Counsel, National Federation of Independent Business (NFIB) | Support rescission | Business trade association / advocacy org | AUTH CAPFORM CB CBA IMMAT |
Position: Support rescission (majority) · Entity: Business trade association / advocacy org (unanimous) Modification posture: No modification requested — no substantive request to change the framework AUTH Statutory authority / major-questions (either direction) — “the SEC lacked authority to issue them” CAPFORM Market efficiency / capital formation — “at odds with the Commission's policy objectives of facilitating capital formation and promoting public company status” CB Compliance burden — “time-consuming, costly, and unwarranted burdens on America's small businesses” CBA Cost-benefit assessment — “impose substantial costs on public companies and their shareholders that are not justified by the informational benefits they may provide to some investors” IMMAT Immaterial / not decision-useful — “provides investors, at great cost, with an avalanche of information that is unlikely to be material to the decision-making of a reasonable investor” | |||||
| ▾ July 26, 2026 1 letter | |||||
| ▸93 | July 26, 2026 | Rina Webster | Oppose rescission | Individual | Fallback / Compromise CAPFORM CB CBA CFR CMP DEMAND FRAG INSUFF IP WHIP |
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 CAPFORM Market efficiency / capital formation — “a result in tension with the Commission's own stated interest in U.S. capital markets competitiveness” CB Compliance burden — “Rescission Does Not Reduce Compliance Burden — It Fragments It” CBA Cost-benefit assessment — “The Cost-Benefit Analysis Understates Costs to Investors and Capital Formation” CFR Climate-related financial risk — “climate-related transition risk, physical risk, and regulatory risk have become more material to valuation and cost-of-capital analysis across a widening range of sectors since 2024” CMP Standardization / comparability — “Reduced comparability across issuers raises due-diligence costs for investors and widens the information gap between institutional investors” DEMAND Investor demand / fund reliance — “The Rule Was Adopted to Meet Investor Demand That Has Not Diminished” FRAG Regulatory fragmentation / multi-jurisdictional consistency — “Registrants have already built compliance infrastructure — data systems, internal controls, and personnel — to meet Scope 1 and Scope 2 reporting obligations, much of it built to align simultaneously with California's SB 253 and SB 261 and the EU's CSRD/ESRS framework.” INSUFF Insufficient / incoherent legal basis (either direction) — “When an agency reverses a settled policy, it must supply a reasoned explanation and must grapple with serious reliance interests that have grown up around the existing rule — it may not simply substitute a new policy preference for the old one.” IP Investor protection / decision usefulness — “As an investor who weighs climate-related transition and physical risk in my own capital allocation decisions, I rely on standardized, comparable emissions and risk disclosure to evaluate the companies I invest in.” WHIP Regulatory whiplash / reliance interests / costs already incurred — “Investors, in turn, have begun incorporating the expectation of standardized federal disclosure into their own analytical models.” | |||||
| ▾ July 24, 2026 3 letters | |||||
| ▸95 | July 24, 2026 | Rockford Bona | 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 | |||||
| ▸94 | July 24, 2026 | Jonathan Whitson, Retired | Support rescission | Individual | ACCT |
Position: Support rescission (unanimous) · Entity: Individual (unanimous) Modification posture: No modification requested — no substantive request to change the framework ACCT Stewardship / accountability — “I firmly believe that any company that focuses on anything else should have the board of directors removed.” | |||||
| ▸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 2 letters | |||||
| ▸123 | July 22, 2026 | Francis Fortin, Chief Investment Officer, FERIQUE Fund Management | Oppose rescission | Investor / asset manager (institutional) | Fallback / Compromise CB CFR CMP DEMAND FRAG IP GHG12 GOV |
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) CB Compliance burden — “Many companies already face climate-reporting requirements under California, EU, and other international frameworks” CFR Climate-related financial risk — “Investors use climate-related information to assess risks affecting company value, such as transition risks” CMP Standardization / comparability — “Standardized disclosures improve consistency and decision-making.” DEMAND Investor demand / fund reliance — “the Global Investor Statement to Governments on the Climate Crisis” FRAG Regulatory fragmentation / multi-jurisdictional consistency — “Many companies already face climate-reporting requirements under California, EU, and other international frameworks.” IP Investor protection / decision usefulness — “Climate-related financial information is an important input into our fundamental research, valuation, and risk management processes supporting investment decisions” | |||||
| ▸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” | |||||