SEC Publishes Sample Comment Letter Regarding Climate Change Disclosures

The SEC’s Division of Corporate Finance has posted a “Sample Letter to Companies Regarding Climate Change Disclosures.”  The letter provides insight into the nature of information and response being requested from identified registrants regarding the SEC’s 2010 guidance on climate-related disclosures. In the sample letter, the SEC requests that identified companies provide additional climate-related information to support the SEC’s understanding. Among other items, disclosure matters could be considerations for including “more expansive disclosures” in the company sustainability reports than their SEC filings, “material effects of transition risks related to climate change that may affect your business,” and “material litigation risks related to climate change.”

Based on feedback from our clients and the markets we serve, it is our understanding that the SEC has already started the process of distributing these comment letters to identified companies. For more information, contact us. We are here to help.

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