Securities and Exchange Commission Publishes Climate Change Disclosure Guidance, Maintains Enhanced Focus on Climate Change Disclosure
Before beginning, I should let readers know that I have sources noted in a Word version of this post but cannot insert footnotes or endnotes in this post. If you are interested in the citations, please leave a comment. Introduction On September 22, 2021, the U.S. Securities and Exchange Commission (the " Commission ") published a Sample Letter to Companies Regarding Climate Change Disclosures (the " Sample Letter "). The Sample Letter is just the most recent example in a growing list of Commission statements and actions related to climate change-related disclosure, beginning with the Commission's 2010 Climate Change Guidance. Both the 2010 Climate Change Guidance and the Sample Letter ask issuers to assess climate change risks, impacts or litigation within the Commission's current principles- and materiality-based disclosure frameworks, and to disclose climate change-related information if they are material risks, material litigation or have had a material i...