Submitted Comment Name YOONWOO PARK Affiliation N/A Subject Applicability of SB 253/261 to Foreign Parent Companies Message Dear CARB Climate Disclosure Team, Thank you for providing the opportunity to submit public comments. I respectfully request clarification on the following points related to the applicability of SB 253 and SB 261: (1) If a U.S. subsidiary that is doing business in California does not meet the revenue thresholds on a standalone basis, but its foreign parent company not formed under U.S. law does exceed the thresholds based on global total annual revenue—would the reporting obligations under SB 253 and/or SB 261 still apply? (2) In such cases, which entity would be considered the reporting entity — the U.S. subsidiary or the foreign parent company not formed under U.S. law? In addition, should the disclosure report be prepared on a standalone basis (U.S. subsidiary only) or on a consolidated basis (including the foreign parent’s global operations)? Clear guidance on these questions would help multinational companies prepare for compliance. I also suggest clarifying whether and how the revenues of a foreign parent company not formed under U.S. law are counted in “total annual revenue.” Thank you very much for your attention and consideration. File Upload (i.e., Attachments): N/A N/A
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