Fundamental Rethinking of Financial Disclosure

The Securities and Exchange Commission has asked investors and investment advisers to help them engage in “a fundamental rethinking of financial disclosure, beginning with the basic purposes of disclosure from the perspective of investors and markets.” This sounds too good to be true, because in a sense it is. The 21st Century Disclosure Initiative, as it is termed, is primarily focused on harnessing new technologies (hardware and software) to improve reporting, transparency and the usefulness of data. However, the SEC did open the door to a meaningful re-examination of disclosure when they recently asked investors and investment advisors to comment on the following question: “What information that is not required to be filed or furnished with the Commission do investors and others use to make investment decisions or give investment advice?” Needless to say, as strong advocates for SRI we have taken this invitation seriously and certainly have a few thoughts on the subject. Below is our comment letter to the SEC.
Trillium Asset Management Corporation’s Comment to SEC