The SEC’s Climate Proposal – Top Points for Comment

The SEC published in March 2022 a dauntingly complex proposal to require public companies to provide climate-related disclosures.

The period for public comment on the proposal is very short, and it seems clear that a majority of the Commission is determined to proceed quickly.

The proposal is extremely ambitious, and it will place heavy new demands on public companies and the public disclosure system.  We believe that moderating those demands would improve the proposal’s chances of successfully achieving its purposes.

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