From the letter: "The seemingly innocuous RFI questions are actually precursors to MSRB rules that would require municipalities to make ESG-related disclosures. From the Founding, America’s states and their subdivisions have been a cornerstone of her success. These communities require funding, and that means access to capital markets. Recognizing the special role of America’s states and local governments, Congress enacted a unique regulatory regime for them, requiring that they abide by anti-fraud provisions but exempting them from onerous disclosure requirements that would otherwise drive up the costs of funding and threaten their ability to govern themselves. Congress maintained this balance when it created the MSRB, strictly forbidding it to demand disclosures from municipal issuers or to specify the content of disclosures. The MSRB should abandon this information gathering process and the creation of any disclosure rules governing municipal issuers."

 

Read the full letter at: https://sto.idaho.gov/Portals/0/xBlog/uploads/2022/3/24/2022-03-08-Comment-to-MSRB-ESG-Disclosures.pdf