SEC Commissioners, Staff, and Stakeholders:

Douglas Hileman Consulting LLC (“DHC” pr “Commenter”) is pleased to provide comment on the SEC’s proposed rule on climate-related disclosures, released March 21, 2022. DHC submitted public input on June 7, 2021, responding to Commissioner Allison Herron Lee’s request for public input. DHC supported SEC actions on climate-related risk then, as we do now. 
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INTRODUCTION

The author suggests there are three core attributes of sustainability reporting that differ from financial reporting and disclosures. 

• • • • • Control and Influence
        • Quantitative and Qualitative
        • Retrospective and Prospective

Accountants, internal auditors, and assurance providers and others with experience in financial reporting and disclosures are becoming more involved in ESG reporting[1] and disclosures. There are already professionals who have involved in sustainability programs, reporting and reviews as they have evolved.  Understanding these can help bridge the gap.  It can also improve the effectiveness and efficiency of organization’s governance, strategy, risk management – as well as financial performance and positive impact in non-financial areas.

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