Submitted Comment Name Joe Kulik Affiliation N/A Subject SB261 climate-related reporting: Non-US-based Parent Companies Message Related to SB261 climate-related reporting: I’d like to provide input on allowing non-US-based parent companies to self-report to avoid multiple US-based subsidiaries reporting. Allowing parent companies to post 261-compliant reports is essential. This climate-related reporting infers that the reporting entity holds the authority to take actions related to actually managing the identified climate-related risks. A subsidiary is likely subject to a Parent company’s control and influence to the extent that a subsidiary likely lacks the power to act on the risks and opportunities a subsidiary would identify in their own 261-related report. Therefore, I would suggest the rules permit AND RECOMMEND that parent companies submit a 261-compliant report on behalf of their covered subsidiaries. Investors would not be negatively impacted by allowing, or encouraging, parent-company reporting because a 261-compliant report actually provides additional relevant information. File Upload (i.e., Attachments): N/A N/A
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