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Responsible Alpha 的 SEC 气候风险研究被 123 家机构采用

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U.S. fisheries provide important economic benefits in every coastal state. Credit: Global seafood Alliance.

点击此处阅读 Responsible Alpha 为 SEC 做出的评论信

Responsible Alpha 开发了商业、经济和投资分析,供123家环境保护、土著权利和种族正义组织在写给美国证券交易委员会主席加里·根斯勒(Gary Gensler)的信中使用。信中讨论了《投资者气候相关信息披露的增强和标准化》这一拟议规则。

气候相关财务信息披露工作组(TCFD)在其2016年报告中指出:“当今组织面临的最重要、也是最容易被误解的风险之一是气候变化。”这一观点得到了超过345家美国机构的支持。

Responsible Alpha 的分析表明,投资者需要公司披露其气候相关的财务风险和应对策略、温室气体(GHG)排放量、在低碳未来经济中保持生存或繁荣的计划,以及在这些方面的财务韧性。这些信息应与公司所处社区相关联,支持这些社区的发展,因为这些社区常常承受的影响被忽视或低估。

为了进一步加强和支持这一分析,Responsible Alpha 编写了12个商业案例,分别涵盖以下方面:

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U.S. Commercial and Recreational Fisheries Economic Impacts, 2020 Credit: NOAA Fisheries.
 

How receptive are the target beneficiaries to the sustainability goals of the Foundation?

 

  • Participants in the permit bank programs agree, in terms of participation, to abide by sustainability goals consistent with those of the Foundation. Fishers frequently expressed the wish for better science and more agile application of science to fisheries management.

 

What is the relationship between sustainability and access to finance?

 

  • There is no sustainability premium, so there is not the financial incentive for taking fewer fish or taking fish more carefully. Access to finance can improve sustainability in the right circumstances, by for example allowing fishers to purchase more selective gear or more efficient boats, but this can only be the case when the market signals support the additional costs.

 

What financial options are available to the target beneficiaries?

 

  • Financial options are limited. The inability to collateralize assets is the main reason for this. Banks, it was broadly argued in our interviews, do not understand fisheries. They would not know what to do with assets that they could end up holding. This was not always a problem; earlier generations of bankers worked closely with fishermen, but as the relative economic importance of fishing has declined, bankers have not prioritized understanding fisheries. Older bankers more familiar with the industry are retiring, and new ones lack exposure to it.


Are the tools designed sub-optimally for uptake?

 

  • The constraint of the permit banks is capital to buy permits and quota as they come available. As fishers retire or cash out of the industry, they put their assets on the market. Since permits are limited, they do not stay on the market long. Liquidity determines who can buy the permit. Unless permit banks have a line of credit or cash on hand, they may miss opportunities to capture catch-share quota for the community.

 

Do the financial opportunities promoted by the Foundation fit inside existing Small Business Administration (SBA) and similar national and state/regional lending authorities’ business lending models?

 

  • The financial opportunities promoted by the Foundation do not fit into any identified governmental model.

 

Can single paperwork be used for multiple loan granting programs (e.g., SBA, the Foundation, etc.)?

 

  • The dearth of loan programs means that there is not a critical mass of financial instruments that could benefit from a single paperwork approach.

 

Do loan criteria match certification criteria for sustainable fishing certifications (e.g., Marine Stewardship Council, corporate buyer criteria, corporate buyer ESG policies, etc.)?

 

  • No existing loan programs with sustainability certification criteria were identified in the USA.

 

What are the unmet financial needs of vessel owners/operators?

 

  • Access to loans.

  • Access to affordable insurance.

  • Access to predictable markets.

  • Assistance with the costs of changing gear for new regulations or to enter into new fisheries.

  • Premium for biological and cultural sustainability.

 

Are proposed interventions accretive to revenue while increasing risk mitigation?

 

  • Proposed interventions discussed can increase risk mitigation, except as far as improved access to capital heats the permit market, producing risks to fishers due to the high costs of quota. The burden for fisheries is the inability to fish due to lack of quota, on the one hand, and the pricing of the quota on the other.


How do the target beneficiaries approach financial risk and opportunity?

 

  • Most successful fishers have a business plan or seek help to develop one. They manage their businesses effectively, and to the extent possible, quantify financial risk and opportunity.

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2020 National Commercial Ex-Vessel Revenue Change. Credit: NOAA Fisheries.

 

What criteria do they use in making financial decisions (e.g., terms of a loan, size of a loan, duration of a loan, guarantees or collateral required, form in which funding is received)?

 

  • Most indicated that the risking price of quota has stretched the payback period from 6 to 7 years to 10 to 12 years. Rising interest rates are a compounding factor.

 

What financial options are commonly available to the target beneficiaries?

 

  • The only identified options are loans (when they get them) and leases of quota.

 

How does the length of loan fisheries forecast and trends?

 

  • There are no forecasts of prices for a variety of factors. The first is the decentralization of the market for buying fish, and lack of uniform infrastructure, meaning that there is no easy method of comparing or monitoring prices. Long term projections of value from a fishery are non-existent, and the payback period is increasing. These factors contribute to the unbankability of fishing.

 

What collateral might be required for participation in a financial solution?

 

This could take different forms:

 

  • Government loan guarantees.

  • A blended finance approach

  • A bond program.

 

Examples of collateral could include:

 

  • Business assets: Vessel, permit, and / or quota valuation after addressing depreciation.

  • Business assets: On-shore capital such as docks, sheds, and storage facilities.

  • Personal assets: In a last resort, and not recommended, personal mortgage.

 

What are the major obstacles to access to finance?

 

  • All of these are obstacles, but the binding constraint is the fact that the major asset of a fisher is “tied” capital that cannot be used for collateral. That is the permit and quota.

 

At which breakeven point or price point does a sustainability-linked loan become profitable for the fisher?

 

  • A breakeven point is impossible to predict without better market intelligence.

 

Are there “soft prepayment” terms in the loan in case equipment is sold and the borrower does not then face a penalty for prepaying?

 

  • We found no evidence of such terms, but we did not do an exhaustive survey.


Does a secondary market exist for “sustainable equipment” so if the equipment is underutilized due to declining fishery, fishers can sell equipment to pay off the loan?

 

  • There is a secondary market for equipment, but sustainable equipment does not exist as an asset class.

 

Does a sustainability loan improve corporate buyer interest of harvested fish, long-term contracts, or fisher’s margins?

 

  • This is untestable without concrete sustainability loans. We did hear that a consistent, high level of catch will build a market though – potentially increasing demand and price.


How do the target beneficiaries approach financial risk and opportunity?

 

  • Interviews revealed that most fishers are sophisticated in their financial decision makings. They are not risk   averse, but they are careful in evaluating the risks and benefits of financial choices.

 

Which transition risks could affect the creditworthiness of the target beneficiaries?

 

  • Policy and legal risks, including quota fluctuations

  • Technology risks include the growth of lab-grown fish replacement products

  • Market risks include the inability to obtain transparent near-term prices (e.g., one week, two weeks, etc.).

  • Reputational risks include consumer preference changes, impact of NGOs on labeling of fisheries “sustainable or unsustainable.”

  • Acute and chronic climate risks, with substantial risks of     stranded assets due to displacement of fish stocks (resulting in the wrong combination of vessels and permits to respond to the changes in the fisheries).

 

How do preferences compare demographically?

 

  • Fishers approaching retirement typically received an initial quota when IFQs were introduced, at no cost. Fishers entering the fishery face much more risk due to high debt loads or capital outlays, which requires greater financial acumen.

 

Does the target beneficiary have a preferred lending institution?

 

  • Preferences vary by region. National financial institutions for the Gulf Coast and New England fisheries, and state-level First Nations or regional financial institutions in the Alaska fisheries. In either case, fishers preferred efficient and effective financial institutions.


How do psychographic factors influence choice? What is the role of peer pressure?

 

  • In some cases, especially in the Cape and Islands, there is a close-knit fishing community. This reflects in preference for small-scale fisheries where the benefits of the fishery are not purely financial, but are also important to community self-identity and heritage.


Are borrowing decisions made individually, by the family, by the fishing co-op, etc.?

 

  • Borrowing decisions are made individually, and most frequently within the family.


Do the target beneficiaries demonstrate loss aversion in their capital budgeting processes?

 

  • Most fishers interviewed were mindful of unexpected expenses due to equipment failure or loss and budgeted for replacement.

 

Do the target beneficiaries demonstrate herding behavior?

 

  • This happens in the choice of gear and target fishery. When conventional wisdom changed, they would exit a fishery because it had become overcrowded with belated entrants attracted by their success. This is exacerbated by a lag in regulation, which manifests as a management measure to solve a problem after it occurs, rather than prevent it in the first place.

 

Do the target beneficiaries have a resistance to the proposed sustainable fishing technology?

 

  • There is strong resistance to “ropeless” fishing in the lobster industry in Maine. Great care will need to be taken in introducing such mandates, including the consideration of options such as compensation for losses and financial support for transition.

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Responsible Alpha 为各机构向低碳、可持续和公平的未来转型提供建议。

Responsible Alpha 是一家在特拉华州注册的公益公司,由其员工、顾问和董事会成员自豪拥有。

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