Status: Draft -- Not PublishedWill be live at 02/14/2017 00:00
IIF-GFMA Joint Response - TFCD Climate-related Financial Disclosures
Tuesday, February 14, 2017
In the letter, the Associations are supportive of the objective of greater public disclosure of financial risks arising from climate change and policy responses thereto, where material and relevant to the business of a given issuer.
The Associations generally support the goal of putting climate-related financial disclosures into mainline financial statements, but there will need to be evolution over time toward this goal, and it must be clearly understood that the recommended disclosures are not intended to expand the otherwise-applicable scope of audit requirements or legal liability.
The letter proposes that the Task Force consider a two-step approach through materiality assessment of disclosure of scenario analysis to the application of such analysis suggested in the Recommendations.
The Associations support the concept of developing standard climate scenarios and time horizons for climate-related financial disclosures, but consider that further work would be required to make them useful.
The Associations are concerned about the suggested disclosure of internal carbon prices and also propose that further work be done to consider whether common price metrics or references should be developed.
The letter also mentions that the final Recommendations should be clearly identified as making suggestions that may be used in meeting accounting standards, but should not be considered in any way to modify such standards or the available official guidance