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The following letter was sent on July 25, 2023 and signed by Animal Legal Defense Fund, Family Farm Defenders, Farmworker Association of Florida, Food & Water Watch, HEAL Food Alliance, In Defense of Animals, Institute for Agriculture and Trade Policy, National Family Farm Coalition and Union of Concerned Scientists. 

Dear Chairs McHenry and Wagner and Ranking Members Waters and Sherman:

The undersigned organizations would like to take this opportunity to submit the following comment on the hearing entitled, “Oversight of the SEC’s Division of Corporation Finance.”

We know that farmers and ranchers of all sizes are increasingly taking advantage of significant business opportunities and financial incentives for sustainable agricultural practices and products—many of which attract new customers, green premiums, and new investment.

However, we are concerned that some members of this committee have made misleading claims1 that the Securities and Exchange Commission’s proposed rule for Enhancement and Standardization of Climate-Related Disclosures for Investors (RIN 3235-AM87) would cause substantial burdens to farmers. These harmful claims promote messaging from agribusiness companies and their lobby,2 undermine corporate disclosure requirements,3 and distract from the real material risk that climate change—not climate disclosure—poses to our members' lives and livelihoods.

This letter provides an overview of the current challenges in industrial agriculture as a result of market consolidation and how climate financial risk harms not just investors, but other critical stakeholders, including farmers, farm workers, and consumers. Members of this committee have invoked concern for these stakeholders as grounds to oppose a robust climate-disclosure rule, so it is important to hear from groups like ours that represent these constituencies rather than only the industrial farm lobby.

To continue reading the letter, please download a PDF