October 3, 2022

CII Comments on SEC Plans to Update Disclosure Framework

Last week, CII submitted a comment letter on the SEC’s draft 2022-2026 strategic plan and offered suggestions on the Commission’s proposals to update its disclosure framework. The letter generally supports the Commission’s overall plans to modernize the design, delivery and content of corporate disclosure. Specifically with respect to sustainability disclosure, CII recommends that the SEC work with other regulators and standard setters, including the International Sustainability Standards Board, to limit “disclosure fragmentation in the global markets.”

CII also advises the SEC to evaluate the following factors when adopting rules to update its disclosure framework:

– Materiality to investment and voting decisions;
– Depth, consistency and reliability of empirical evidence supporting the connection between the disclosure and long-term shareowner value;
– Anticipated benefits to investors, net of the cost of collection and reporting; and
– Prospect of substantially improving transparency, comparability, reliability and accuracy.

CII’s letter also supports the SEC’s plans to require companies to use iXBRL format and reiterates CII’s request that SEC correspondence with public companies be made available in a structured, machine-readable format.

– Dave Lynn