Letter to ISSB re: Consultation on Agenda Priorities

Dear Mr. Faber:

The American Bankers Association (ABA) appreciates the opportunity to comment on the International Sustainability Standards Board’s Request for Information – Consultation on Agenda Priorities ("RFI"). The RFI asks stakeholders for their views on the strategic direction of the ISSB and the balance of its activities, including a proposed list of new research and standard-setting projects that could be added to its work plan. ABA members consist of lenders, investment bankers, asset managers, investment analysts and asset custodians and, consequently, bring perspectives from both the users of the information as well as the preparers. Therefore, we bring perspectives from a wide range of stakeholders.

Supporting the implementation of the Inaugural ISSB Standards should be – far and away –the highest priority of the ISSB.

(Responding to Question 1 of the RFI)

The issuance of IFRS S1 (General sustainability-related disclosures) and IFRS S2 (Climate-related disclosures) is a significant milestone within the field of international sustainability reporting and ABA observes that certain countries appear eager to approve S1 and S2 as standard benchmarks within their disclosure regimes. With year-end 2024 effective dates, companies will be hard-pressed to design, test, and implement systems that comply with the new standards, especially considering sustainability-related auditing standards (which will guide internal control systems) are not expected to be issued until late 2024. In addition to addressing material climate-related risks, scenario analysis, and greenhouse gas emissions (GHGs) as of the year-end date, controls over systems and processes will need to be implemented to address the many foreseeable questions from stakeholders related to year-to-year changes in both current activity, forward-looking forecasts, and comparisons to targets. If stakeholders are expecting comparable and consistent disclosures between companies, significant work will be needed to address these issues, which are not directly mentioned within S1 or S2.

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