Last week, Allison Lee, Acting Chair of the SEC, directed the
staff of Corp Fin to "enhance its focus on climate-related
disclosure in public company filings." Yesterday, the SEC
announced that the new climate focus would not be limited to Corp
Fin—the SEC has created a new Climate and
ESG Task Force in the Division of Enforcement. According to
the press
release, the initial focus of the Task Force will be to
identify any material gaps or misstatements in issuers'
disclosure of climate risks under existing rules, giving us all
another reason to excavate the staff's 2010 interpretive
guidance regarding climate change. (You may recall that
the guidance addressed in some detail how existing disclosure
obligations, such as the Reg S-K requirements for business
narrative and risk factors, could apply to climate change.
See
this PubCo post.) Apparently, however, the remit of the Task
Force goes beyond climate to address other ESG issues. Lee said
that the Task Force is
