Thanks for the post. I think it’s worth your time and our attention. I tend to agree with you… do you think a similar reasoning (i e., that you can leverage your impact by pressing “meta”-regulators) would apply to EEUU (eg., the European banking authority), too? And /or to TCFD?
On the other hand, it seems that you think individual contributions could have an impact, right? This conflicts with my anecdotal experience with public consultations—where usually interest groups and personal connections tend to be prioritized by policy-markets (who can’t really pay attention to all the messages they receive). But if you’re right, would it be convenient to draft some guidelines or even a token for messages to be addressed to SEC?
Typically, you are correct that individual comments have a low weight. But, I believe the general counts positive/negative are taken into account. Also i) even if there is only a small chance, say 9%, of any one comment have weight—given the cost of a comment is low, it’s still a good return and ii) I do think number of comments does have weight (say, a 79% chance this is true).
Re: TCFD
TCFD does not have legal weight (except where governments/regulators decide to use it as such) and is not as globally influential as the SEC.. So the meta-regulator effect of TCFDs is much lower than the SEC, I’d say close to zero maybe 2% or 3%, if SEC is at least 40% and possibly I’d lean higher.
Re: EU
While EU has more weight than TCFD, it also does not have the same meta-regulator impact as SEC, as US business and economy is more influential and SEC has more global influence on international companies. I’d estimate 5 or 6% at best. There is actually already some EU (and UK) regulation in this respect.
Other meta-regulators...
In this sense the IFRS / ISSB work is more influential globally (but has limited weight of law and is technocratic), but still the SEC has the weight of law and is arguably the strongest (for good or bad) of the possible meta-regulators in this area (also the downstream nd upstream effects eg then asking suppliers to audit carbon). The SEC proposals also have (while contested and technocratic ) a partial political legitimacy if they make it though.
I will consider writing up a short template for people this week. So they can consider. Thanks so much for feedback and comments.
Thanks for the post. I think it’s worth your time and our attention. I tend to agree with you… do you think a similar reasoning (i e., that you can leverage your impact by pressing “meta”-regulators) would apply to EEUU (eg., the European banking authority), too? And /or to TCFD? On the other hand, it seems that you think individual contributions could have an impact, right? This conflicts with my anecdotal experience with public consultations—where usually interest groups and personal connections tend to be prioritized by policy-markets (who can’t really pay attention to all the messages they receive). But if you’re right, would it be convenient to draft some guidelines or even a token for messages to be addressed to SEC?
Re: influence of public
Typically, you are correct that individual comments have a low weight. But, I believe the general counts positive/negative are taken into account. Also i) even if there is only a small chance, say 9%, of any one comment have weight—given the cost of a comment is low, it’s still a good return and ii) I do think number of comments does have weight (say, a 79% chance this is true).
Re: TCFD
TCFD does not have legal weight (except where governments/regulators decide to use it as such) and is not as globally influential as the SEC.. So the meta-regulator effect of TCFDs is much lower than the SEC, I’d say close to zero maybe 2% or 3%, if SEC is at least 40% and possibly I’d lean higher.
Re: EU
While EU has more weight than TCFD, it also does not have the same meta-regulator impact as SEC, as US business and economy is more influential and SEC has more global influence on international companies. I’d estimate 5 or 6% at best. There is actually already some EU (and UK) regulation in this respect.
Other meta-regulators...
In this sense the IFRS / ISSB work is more influential globally (but has limited weight of law and is technocratic), but still the SEC has the weight of law and is arguably the strongest (for good or bad) of the possible meta-regulators in this area (also the downstream nd upstream effects eg then asking suppliers to audit carbon). The SEC proposals also have (while contested and technocratic ) a partial political legitimacy if they make it though.
I will consider writing up a short template for people this week. So they can consider. Thanks so much for feedback and comments.
In case you’re still interested in the subject: Consultative document—disclosure of climate-related financial risks (bis.org)