This comment focuses on two of the central questions in the PRA review process: 1) the necessity of the proposed information collection for agency operations, and 2) ideas to improve the quality and clarity of the information collected. The disclosures will assist the State Department to manage the national emergency declared by the President with respect to Burma by enabling it to target investors whose operations and policies raise red flags for potential contibution to human rights abuses, corruption, and armed conflict...ERI will use the disclosures in conjunction with Burmese groups for aims that are complementary to those of the government, i.e. to identify business practices that raise human rights concerns and to engage with and, where necessary, hold to account investors who contribute to human rights abuses. [Refers to Ivanhoe Mines]