The U.S. Impact Investing Alliance submitted a formal comment letter to the U.S. Securities and Exchange Commission opposing its proposal to rescind the climate-related disclosure rules that had been previously adopted in March 2024 (File No. S7-2026-19).

The Alliance’s letter urges the SEC to retain the rules, which give investors comparable and relevant information about the financial risks that companies face from a changing climate. Markets, credit rating agencies, insurers and banking regulators already treat climate-related risk as financially consequential, and the existing rule is a modest and materiality-bound measure that fits squarely within the SEC’s longstanding disclosure authority. The Alliance also cautions that the legal theory advanced to justify rescission reaches far beyond climate, and, if adopted, could lead to further rescission of a much wider range of disclosures that investors rely on to make informed decisions on risk.

“Investors asked for this information because climate risk is financial risk, and rescinding these rules would leave them with less of the comparable and reliable data that our markets depend on,” said Fran Seegull, President of the U.S. Impact Investing Alliance. “The deeper concern is whether the Commission is diluting its own authority and undermining its own mission of maintaining fair, orderly and efficient markets.”

The Alliance’s position builds on longstanding advocacy for greater transparency for investors on financially relevant factors, including support for the proposed climate disclosure rule in 2022 and recent comments on the Commission’s review of Regulation S-K.

Read the Alliance’s full comments.