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Environmental Social & Governance (ESG) SEC Comment Letter Process

WilmerHale

SEC Staff Comment Letters Continue to Seek Enhanced Climate-Related Disclosures

WilmerHale on

While the Securities and Exchange Commission’s (SEC) new climate-related disclosure rules remain pending, recent comment letters show that the SEC staff is not waiting for the rules to be finalized in order to seek more...more

Sullivan & Worcester

The Status of Two Pending Rules That Would Require Disclosure of Climate Risks

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We discuss the status of two pending federal regulations that would require the disclosure of information concerning greenhouse gas (GHG) emissions and climate-related risks: one proposed by several agencies that would apply...more

Cadwalader, Wickersham & Taft LLP

In Depth: Dissecting the Real Estate, Structured Finance and Financial Services Industries' Comment Letters on the SEC’s Climate...

By the time the comment period closed on June 17, 2022, the SEC had received thousands of comment letters from the public in response to the SEC’s proposed climate disclosure rules (the “Proposal”), which is perhaps the most...more

Jones Day

Comment Letter Submitted on SEC’s Proposed Climate-Related Disclosure Rules

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We believe our proposed changes support all market participants' common objectives of investor protection and fair and efficient capital markets. ...more

Vinson & Elkins LLP

[Webinar] Navigating the 2022 Annual Meeting and Reporting Season - January 12th, 9:00 am - 12:00 pm CT

Vinson & Elkins LLP on

In this program, we will focus on SEC developments affecting, and practical aspects of preparing for, public companies’ annual meetings and annual reports, including key Environmental, Social and Governance (ESG) themes. We...more

Sheppard Mullin Richter & Hampton LLP

SEC Publishes Sample Letter to Companies on Environmental Disclosures

Environmental, social, and governance factors (“ESG”) have pushed to the forefront of the SEC’s attention in recent years. In September, building on prior guidance, the SEC’s Division of Corporate Finance released a sample...more

Dorsey & Whitney LLP

Governance and Disclosure Considerations from the SEC’s Climate Change Comment Letters

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The SEC’s Division of Corporation Finance has issued a sample comment letter, and sent actual comment letters to a series of public companies, asking for additional Form 10-K disclosure on topics addressed in the SEC’s 2010...more

BCLP

Have You Updated Your Approach to MD&A?

BCLP on

The next Form 10-K filing for most companies will be their first filing required to comply with the revised Management’s Discussion and Analysis (Item 303 of Regulation S-K) requirements adopted by the SEC in November 2020....more

White & Case LLP

SEC Issues Sample Comment Letter as it Ramps Up Scrutiny of Climate Disclosures

White & Case LLP on

On September 22, 2021, in a step that emphasizes the SEC's increased focus on climate change disclosure, the SEC's Division of Corporation Finance ("Corp Fin") issued a sample letter for public companies containing comments...more

Sullivan & Worcester

SEC Issues "Sample" Climate Change Disclosure Comment Letter

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As part of the SEC Division of Corporation Finance’s focus on climate-related disclosure in public company filings, and as a follow up to guidance on this topic issued in 2010, the Division posted an illustrative letter...more

Goodwin

SEC Publishes Sample Climate Change Comment Letter

Goodwin on

The staff of the Division of Corporation Finance (“Staff”) of the U.S. Securities and Exchange Commission (“SEC”) published a sample comment letter on climate change disclosures on September 22, 2021. A brief statement that...more

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