Comment Text:
We understand that
The Energy and Environmental Markets Advisory Committee (EEMAC) held a public meeting on Thursday, June 3, 2021 to examine how derivatives markets can facilitate the transition to a low carbon economy, including the status of carbon reduction through cap-and-trade and
other carbon trading market mechanisms.
As we noted in 2015 (see: https://www.creativeinvest.com/UKConsultationonChangestoInvestmentRegulationsApril222015.pdf)
"As the market value of environmental, social and governance factors continues to grow, companies and investment managers will engage in fraudulent practices related to these factors. These practices will range from simple falsification of environmental, social and governance records to more sophisticated, but no less fraudulent methods related to environmental, social and governance ratings. We note that unethical practices have flourished in capital market institutions, propelling ethical standards of behavior downward. Thus, unethical behavior has become standard in the financial services marketplace. We incorporate the following comments by reference:
Comments on Proposed Rule:
Executive Compensation and Related Party Disclosure
[Release Nos. 33-8655; 34-53185; IC-27218; File No. S7-03-06]
http://www.sec.gov/rules/proposed/s70306/wcunningham6601.pdf
Comments on Proposed Rule:
Internet Availability of Proxy Materials
[Release Nos. 34-52926; IC-27182; File No. S7-10-05]
http://www.sec.gov/rules/proposed/s71005/wcunningham5867.pdf
Comments on Proposed Rule:
Security Holder Director Nominations
[Release Nos. 34-48626; IC-26206; File No. S7-19-03]
http://www.sec.gov/rules/proposed/s71903/wmccir122203.pdf
Comments on Proposed Rule:
Definition of Nationally Recognized Statistical Rating Organization
[Release Nos. 33-8570; 34-51572; IC-26834; File No. S7-04-05]
http://www.sec.gov/rules/proposed/s70405/wcunningham9442.pdf
Comments on Proposed Rule:
Securities Offering Reform
[RELEASE NOS. 33-8501; 34-50624; IC-26649 International Series Release No. 1282 File No. S7-38-04]
http://www.sec.gov/rules/proposed/s73804/cunningham013105.pdf"
