Submitted Comment Name Julie Robinson Affiliation N/A Subject SB253/261/219 “Who”: Covered Entities Message Hi, The following issue was touched on during both of the workshops held by CARB, however there remains uncertainty over some of the issued guidance. This is regarding the definition of the Covered Entity (Being: “Covered entity” means a corporation, partnership, limited liability company, or other business entity formed under the laws of the state, the laws of any other state of the United States). CARB have also recognised that, if a subsidiary of a parent company qualifies as a covered entity under HSC § 38533, the subsidiary is not required to prepare a separate climate-related financial risk report (if the parent company is reporting on its behalf). However, further to this, the question has arose if a non-US parent can use their reporting to cover their subsidiaries reporting obligations. We would like to clarify if it is appropriate to report under a non-US parent rather than at the level of highest US-based entity. As this would be disclosing at a higher level, we would infer that this is going above and beyond the legal requirements. Will there be a clarification on this point in the October 14th rulemaking notice? Many thanks, Julie Robinson The Weir Group PLC File Upload (i.e., Attachments): N/A N/A
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