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Pheniece Jones 
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703.875.8974 
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PSC Submits Proposed Rule Comments to SEC Leadership    Comments highlight opportunities to focus and improve disclosure requirements

 
Arlington, Va. (Jun. 24, 2022) The Professional Services Council (PSC) has submitted comments to the Securities and Exchange Commission (SEC; the Commission) on two recent sets of proposed rules, which have critical implications for federal contractors supporting the federal government’s missions. 

“PSC often submits comments in response to proposed rules or requests for information as they pertain to government services contracts. We have not historically provided comments on SEC rulemaking activities,” said Stephanie Kostro, PSC’s Executive Vice President for Policy. “However, the Commission’s recent requests for feedback touch on issues of high importance to PSC’s member companies, prompting us to identify key areas of improvement on cybersecurity- and climate-related disclosures.” 

Joining multiple organizations in a letter on the Cybersecurity Risk Management, Strategy, Governance, and Incident Disclosure proposed rule, PSC noted that “the SEC’s proposed rules neither recognize nor align with the evolving cybersecurity standards and disclosures required of these contractors,” such as the Department of Defense’s evolving Cybersecurity Maturity Model Certification program. These comments encouraged the SEC to “consider the potentially contradictory, unnecessarily duplicative, or financially burdensome nature of its proposed rules when compared with the CMMC requirements” and discouraged the Commission from holding companies to a higher standard of cybersecurity than what is required of government agencies.

In comments submitted on the Enhancement and Standardization of Climate-Related Disclosures for Investors proposed rule, PSC urged the Commission to research, leverage, and if necessary, build upon existing reporting requirements in any final rule rather than create duplicative ones that add to a company’s compliance costs without offering novel data or information. PSC also noted that the SEC should make every effort to limit climate-related disclosure requirements to information that is material to investors’ decisions.

“Both sets of proposed rules would benefit from more time for industry input,” continued Kostro. “We value the SEC’s goals to address significant issues and inform potential investors through improved information sharing between the government and private sector, but requirements should leverage existing reporting mechanisms and be material to investors’ decision-making. PSC looks forward to providing additional industry feedback and working with the Commission to focus and improve their rulemaking.”

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