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S&P Global's report on SEC Chair Clayton's remarks at the Investment Company Institute's recent Annual Membership Meeting reveal that he is continuing to think about how human capital management could be integrated into our principles-driven and materiality-based disclosure scheme in a way that makes sense given the industry and company-specific nature of potentially relevant metrics.

"Forty years ago, our rules said, 'tell us about your plant, property and equipment; tell us about your hard capital assets and what they mean to your business,'" he said. "If I'm an investor, looking at businesses today, I want to know what you're doing with your human talent — how you're growing your human talent, how you're accessing new talent, how you're retaining existing talent, how you're enhancing it."

But Clayton added that he was moving slowly on any proposed changes.

"I'm very cautious because a metric that makes sense in the pharmaceutical industry about human capital is probably going to be nonsensical in the shipping industry," he said. "I think we should be pushing in this direction, but to pick a metric around human capital that would be applicable across all aspects of our economy — you're going to be over inclusive, under inclusive, you're going to miss the mark."

Clayton said he was looking at the questions investors were asking companies now about human capital for guidance.