Re: Draft ICI letter in response to California Air Resources Board Information Solicitation to Inform Implementation of California Climate-Disclosure Legislation
SEC Rules CommitteeSUBJECTS:State IssuesRE:Re: Draft ICI letter in response to California Air Resources Board Information Solicitation to Inform Implementation of California Climate-Disclosure Legislation
The California Air Resources Board (CARB) has issued an Information Solicitation to Inform Implementation of California Climate-Disclosure Legislation: Senate Bills 253 and 261, as amended by SB 219.[1]
In the attached draft comment letter, we:
- advocate that investment companies be excluded from the reporting requirements of both Acts;
- argue that consistent with the Greenhouse Gas Protocol, reporting on managed assets be permitted but not required; and
- assert that investment companies do not meet the legislation's scoping definitions.
Comments are due to CARB on March 21, 2025. Please submit any comments on the draft letter to joshua.weinberg@ici.org by Friday, February 28, 2025.
Joshua Weinberg
Associate General Counsel, Securities Regulation
Notes
[1] Available at https://ww2.arb.ca.gov/sites/default/files/2025-01/ClimateDisclosureQs_Dec2024_v2.pdf.
For a summary of California's Climate Accountability Package, see ICI Memo 35482 (Oct. 10, 2023), available at https://www.ici.org/memo35482. For a summary of ICI's prior Advocacy on California Climate Accountability Package, see ICI Memo 35728 (June 3, 2024), available at: https://www.ici.org/memo35728.