Proposed Rule Regarding the Enhancement and Standardization of Climate-Related Disclosures for Investors

The First Nations Financial Management Board (“the FMB”) is pleased to provide comments on the proposed rule by the U.S. Securities and Exchange Commission (“the Commission”), File Number S7-10-22.

The FMB is providing feedback on the proposed rule as climate-related disclosures by SEC registrants will impact investment decisions being made in Indigenous territories. These same investment decisions are central to economic opportunities for Indigenous businesses. Under the United Nations Declaration on the Rights of Indigenous Peoples (“UNDRIP”), states must seek the free, prior and informed consent of Indigenous people before undertaking any projects on their lands or territories; accordingly, when developing projects in traditional territories, businesses, both registrants in the United States and those under the multijurisdictional disclosure system, must report on this requirement because it is material to determining enterprise value.

FMB Comment Letter on S7-10-22

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