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New Climate Guidance Issued to Federal Agencies Conducting Environmental Impact Analyses

On January 9, 2023, the Council for Environmental Quality (“CEQ”) published interim National Environmental Policy Act Guidance on Consideration of Greenhouse Gas Emissions and Climate Change (hereafter, “guidance” or “GHG...more

Update on Securities and Exchange Commission’s Landmark Proposed Climate- Change Disclosure Rulemaking

Things to Consider - Rulemaking - Coordinate closely with trades to ensure their comments reflect concrete information about impracticability and cost; these make a difference in the admin record upon judicial review...more

Litigation and Enforcement Impact of the SEC's Proposed Rules on Climate-Related Disclosure

The Securities and Exchange Commission’s Proposed Rules on Climate-Related Disclosure, released March 21, 2022, represent a significant change in public company disclosure requirements and, if adopted, will have far-reaching...more

Hurdles Ahead for the SEC's New Climate Disclosure Proposal

On March 21, 2022, the Securities and Exchange Commission (SEC) released its much-anticipated proposed rule on climate-related disclosure and accounting, “Enhancement and Standardization of Climate-Related Disclosures for...more

Attestation: Practical Reflections on What the SEC Climate Proposal Will Require

Among the many changes set forth in the U.S. Securities and Exchange Commission’s proposed rules governing climate-related disclosures are the attestation requirements1 covering registrants’ greenhouse gas (GHG) emissions...more

Summary Outline of SEC's Proposed Rule on Climate-Related Disclosure and Accounting

The SEC’s proposed rule on climate-related risks includes amendments to both the financial reporting requirements (Reg S-X) and the narrative disclosure requirements (Reg S-K). The proposal interlinks the new requirements,...more

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