SEC Commissioner Elad Roisman presented further comments on his thinking about ESG disclosures June 22 at the National Investor Relations Institute 2021 Virtual Conference. Roisman touched on three themes and we have extracted the summary elements of his points.
- What precise items of “E,” “S,” and “G” information are investors not getting that are material to making informed investment decisions? He emphasized the focus on traditional materiality and points out that “In carrying out its role as a federal securities regulator, that is where the Commission must continue to focus: it should assess the merits of any potential disclosure requirements against the question of whether a reasonable investor would consider them material—that is, to a company’s financial value.”
- What ESG expertise would be needed internally in SEC? “It is fair to question how our staff is equipped to determine which climate or environmental information—such as various measures of companies’ greenhouse gas emissions, or strategies for adapting to future climate scenarios—is material to an investment decision today.”
- If the SEC were to incorporate the work of external standard-setters with respect to new ESG disclosure requirements: how would the agency oversee them? “Since the world of ESG involves many more stakeholders and more potential areas of expertise than the world of accounting—including in environmental science and others—I fear that the challenges we have grappled with over the course of our history with FASB will be even more difficult to mitigate and manage in this new context.”