Corp Fin Posts 9 Sample Comments On Climate Disclosure

Earlier this year, then acting SEC Chair Allison Herren Lee directed  Corp Fin to focus on climate disclosure. We weren't sure what would be the end result of such a review. Perhaps it will lead to a comprehensive report on how companies are faring. It undoubtedly will help instruct the climate disclosure rulemaking that the Commission will be proposing in the near-term.

What we do know is that the first companies are now receiving comment letters addressing climate based on recent reviews of their Form 10-Ks. And yesterday, Corp Fin posted a sample comment letter with 9 types of comments about climate. The sample comment letter references the SEC's 2010 Guidance Regarding Disclosure Related to Climate Change, and is consistent with that prior guidance, if more direct on a few points.