The U.S. Impact Investing Alliance submitted a formal comment letter to the U.S. Securities and Exchange Commission in response to Chairman Paul Atkins’ January 13, 2026 statement inviting public input on a comprehensive review of Regulation S-K, the SEC’s non-financial disclosure framework.

The Alliance’s letter urges the SEC to preserve existing mandatory, standardized corporate disclosure requirements. Speaking for investors who own and manage assets well in excess of one trillion dollars, the Alliance argues that robust disclosure is not regulatory excess, but the scaffolding upon which efficient and accountable markets depend. In particular, the letter focuses on risk factor disclosure under Item 105, cautioning against reforms that could reduce the issuer-specific information that investors need. The Alliance recommends that the Commission improve the quality and specificity of disclosure rather than narrowing its scope.

“Investors and companies alike benefit when capital markets rest on a foundation of clear and comparable information,” said Fran Seegull, President of the U.S. Impact Investing Alliance. “At a time when investors are increasingly being sidelined in favor of management interests, the SEC’s mandatory disclosure framework is more important than ever and an essential component of the SEC’s mandate to preserve fair and orderly capital markets.”

Read the Alliance’s full comments.