This is the second comment I filed with the Securities and Exchange Commission on its proposal to require climate-change disclosures (Proposal). My first comment, filed on April 12, 2022, explains that the SEC lacks statutory authority to adopt the rules in the Proposal.The second comment gives...

As the U.S. Securities and Exchange Commission considers appropriate “ESG” disclosure mandates, the Financial Economist’s Roundtable contributes to the debate with a statement summarizing its policy discussion. The FER believes financial regulators should limit mandates to matters that...

The SEC’s efforts to standardize climate disclosure have revealed deep divides among the public and among corporate and securities law scholars about the proper scope and goals of climate disclosure reform. This controversy comes at a time when investor demand for ESG investment products is...

The EU Taxonomy Regulation (TR), adopted in 2019, is a key milestone in defining legally sustainable activities. It should be viewed within the context of the climate and energy targets set by the EU for 2030 in order to become climate-neutral by 2050, and constitutes, along with the Sustainable...

We examine whether a shock to the enforceability of Regulation Fair Disclosure (Reg FD) limited its ability to restrict the flow of private information between managers and investors. Prior work provides evidence that Reg FD reduced managers' selective disclosure of material information...

This paper examines conflict minerals disclosure (CMD) as mandated by the Dodd-Frank Act. We rely on a thorough content analysis conducted by the Responsible Sourcing Network on a sample of 122 firms that filed CMDs with the SEC in 2015. We document that firms with long-term oriented incentives,...

The SEC released its long-awaited Climate Disclosure Proposal on March 21, 2022. The Proposal is expansive, the stakes are high, and, predictably, various critical arguments are being advanced in preparation for a potential court challenge. A close review of the Proposal, however, suggests that...

The SEC’s new GHG disclosure rule will likely lead to substantial economy-wide costs exceeding proposed benefits to investors. The reason is that, even though the SEC’s own cost estimate is substantial, it only focused on direct compliance costs of firms and ignored the costs accruing...