In response to the US Securities and Exchange Commission (SEC) Release No. 33-10098, “Modernization of Property Disclosures for Mining Registrants”, Carbon Tracker submitted a comment letter, welcoming the important steps in the Release for improving disclosures.
Our key recommendations:
- consider the implications of a carbon budget for reserves reporting
- update standards so that reporting better reflects underlying economic reality, facilitating more efficient capital markets
- incorporate factors such as climate risk into ‘modifying factors’