Mr. Brent J. Fields
Secretary Securities and Exchange Commission
100 F Street, NE Washington, DC 20549-1090

Re: Business and Financial Disclosure Required by Regulation S-K (File No. S7-06- 16)

Dear Mr. Secretary,

Cornerstone Capital Inc. (dba Cornerstone Capital Group [“Cornerstone”]) appreciates and welcomes the opportunity to submit comments in response to the Commission’s concept release “Business and Financial Disclosure Required by Regulation S-K” (“the Release”).

Founded in 2013, Cornerstone is a financial services firm based in New York.  The mission of the firm is to apply the principles of sustainable finance across the capital markets and enhance investment processes through transparency and collaboration.  In offering investment advisory, investment banking and corporate advisory services, Cornerstone works with asset owners, corporations and financial institutions to promote new research in the field of Environmental, Social and Governance (ESG) analysis, and facilitate capital introductions for organizations around the world engaged in sustainable business practices.

Because our clients are long-term investors, we have a strong interest in the quality of corporate disclosures, and how well they enable us to evaluate risks and make decisions that will affect the long-term health of our clients’ portfolios.  We believe that although current disclosure standards require companies to report on all material issues, companies currently have insufficient guidance regarding disclosure of long-term issues, particularly those related to ESG concerns.

Voluntary sustainability reports separate from financial disclosures have been commonplace for several years.  Standards for voluntary reporting have risen considerably, and these reports are valuable to many stakeholders such as employees, communities and customers.  Yet current ESG disclosures fail the test of quality, comparability, consistency and materiality that would make them useful to investor decision-making.

Our comments reflect our views on how ESG disclosures could be incorporated into corporate disclosures in a manner consistent with existing disclosure standards and expectations.


Read the full text of the letter from John Wilson and the Cornerstone Capital Research team here


John K.S. Wilson is the Head of Corporate Governance, Engagement & Research at Cornerstone Capital Group. He leads a multidisciplinary team that publishes investment research integrating Environmental, Social and Governance (ESG) issues into thematic equity research. He also writes and presents widely about the relevance of corporate governance and sustainability to investment performance for academic, foundations, corporate and investor audiences.