Proposed Climate Change Rules Reach to the Ranch
company that does trade on the Stock Exchange, that company is required to gather data from you regarding your climate-related risks as outlined above. As the SEC explains it, investors need by Caren Cowan, Publisher, New Mexico Stockman & information about climate-related risks— Livestock Market Digest and it is squarely within the Commission’s limate change is being smashed in our authority to require such disclosure in the faces every which way we turn. But public interest and for the protection of who would have thought that the investors—because climate-related risks climate change policy would be making its have presented financial consequences way into your office? those investors in public. That is just what’s fixing to happen. The Not everyone agrees with that stateSecurities & Exchange Commission (SEC) is ment and many believe that the SEC has promulgating new rules that will require gone well beyond its jurisdiction in requiranyone trading on the Stock Exchange to ing these disclosures. The Competitive provide certain climate-related information Enterprise Institute and the Heritage Founin their registration statements and annual dation are among them. Both groups have reports. The proposed rules would require brought experts in who have developed information about a registrant’s climate-re- extensive comments opposing the new lated risks that are reasonably likely to have regulations. a material impact on its business, results of But you need to comment too. The operations, or financial condition. comment deadline has been extended until The required information about cli- June 17, 2022. Your comments may be as mate-related risks would also include simple as you do not have the data to disclosure of a registrant’s greenhouse gas respond to requests for disclosure and/or emissions, which have become a commonly that the profit margin for your ranching or used metric to assess a registrant’s expo- farming operation does not allow for you sure to such risks. In addition, under the to hire the expertise necessary to proposed rules, certain climate-related provide the data. financial metrics would be required in a “The Enhancement and Standardization registrant’s audited financial statements. of Climate-Related Disclosures for InvesYour agricultural business doesn’t trade tors,” Release Nos. 33-11042, 34-94478 on the Stock Exchange, so where’s (March 21, 2022) scope and comment the problem? process for this release remains as stated in The problem is that if you sell any the original Federal Register notice of April product that ends up in the hands of any 11, 2022. That Federal Register notice can
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be found at file:///C:/Users/caren/Downloads/SEC-2022-0494-0001_content.pdf . It is a mere 129 pages. Comments may be submitted by any of the following methods: Electronic Comments • Use the Commission’s internet comment form ( https://www.sec.gov/rules/ submitcomments.htm ). • Send an email to rule-comments@sec. gov. Please include File Number S7-xx-xx on the subject line. Paper Comments • Send paper comments to Vanessa A. Countryman, Secretary, Securities and Exchange Commission, 100 F Street NE, Washington, DC 20549-1090. All submissions should refer to File Number S7-10-22. This file number should be included on the subject line if email is used. To help the Commission process and review your comments more efficiently, please use only one method of submission. The Commission will post all comments on the Commission’s website ( https://www. sec.gov/rules/proposed.shtml ). Comments are also available for website viewing and printing in the Commission’s Public Reference Room, 100 F Street NE, Washington, DC 20549 on official business days between the hours of 10 a.m. and 3 p.m. Operating conditions may limit access to the Commission’s Public Reference Room. All comments received will be posted without change. Persons submitting comments are cautioned that we do not redact or edit personal identifying information from comment submissions. You should submit only information that you wish to make available publicly. The American Farm Bureau Federation (AFBF) joined 119 other organizations in writing letters to get the comment extension. AFBF says proposed rule could reach nearly every farmer and ranch in the nation.
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