Joint Trade Letter to California State Assembly: Opposition to Senate Bill 260

August 17, 2022

TO: All members, California State Assembly

FROM:
California Bankers Association
American Bankers Association
Bank Policy Institute
Securities Industry and Financial Markets Association

We are writing to express concern regarding the inclusion of financed emissions in the disclosure requirements contemplated in SB 260, the Climate Corporate Accountability Act (CCAA), as well as to highlight the high potential for conflict between the bill and climate disclosure regimes currently pending at the federal and international level.

As currently drafted, SB 260 creates a corporate disclosure regime designed to provide emission information to the general public. The bill would require U.S. companies doing business in California to disclose annually audited amounts of Scope 1, 2, and 3 greenhouse gas emissions (GHGs) in accordance with the Greenhouse Gas Protocol (GHG Protocol).1 SB 260 differs from, but is being considered at the same time as the Securities and Exchange Commission’s (SEC) proposal to require GHG disclosures to help investors assess climate-related risk. In addition, significant efforts are underway internationally through the International Sustainability Standards Board (ISSB) of the International Financial Reporting Standards Foundation (IFRS) – in which the SEC is contributing – to create detailed, global climate disclosure requirements that are consistent and interoperable for public companies in the United States and other jurisdictions around the world, including those European countries, that already have climate disclosure requirements for public companies. There is a high potential for conflict between California’s GHG disclosure requirements and the anticipated final SEC regulations and ISSB standards.

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