Securities Law

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Ernst & Young

Rani Doyle

Managing Editor, Securities Law


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Securities Regulation

SEC Staff Scrutiny of Climate Change Disclosures Has Arrived: What to Expect and How to Respond

By Andrew Fabens, Brian Lane, Courtney Haseley, Elizabeth Ising, James Moloney, Lori Zyskowski, Michael Titera, Thomas Kim, and Ronald Mueller, Gibson, Dunn & Crutcher

Recently, the SEC’s Division of Corporation Finance has issued a number of comment letters relating exclusively to climate change disclosure issues. The letters we have seen to date comment on companies’ most recent Form 10-K filings, including those of calendar year companies who filed their Form 10-K more than 6 months ago, and have been issued by a variety of the Division’s industry review groups, including to companies that are not in particularly carbon-intensive industries. Many of the climate change comments appear to be drawn from the topics and considerations raised in the SEC’s 2010 guidance on climate change disclosure. We expect this is part of a larger Division initiative because the letters are similar (although not identical), contain relatively generic comments, and have been issued in close proximity to one another. Accordingly, it is reasonable to expect that additional comment letters will be issued in the coming weeks and months.

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