On September 22, the Securities Exchange Commission (SEC) Division of Corporation Finance released a sample letter that include the type of comments companies may receive regarding their climate-related disclosure or the absence of such disclosure.
The sample letter includes the type of information, action that the SEC may require from companies. These include:
The disclosure of material effects of transition risks related to climate change such as policy and regulatory changes that could impose operational and compliance burdens.
The disclosure of material litigation risks related to climate change.
The identification of material pending or existing climate-change related legislation, regulations, and international accords and any material effect on their business and financial condition.
The identification of material past and/or future capital expenditures for climate-related products.
The disclosure and explanation of the indirect consequences of climate-related regulation or business trends.
The disclosure and explanation of the physical effects of climate change on their operations and results.