• Deborah

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.

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