On Thursday, January 30, the SEC proposed amendments designed to simplify and
modernize MD&A and the other financial disclosure requirements
of Reg S-K. (See
this PubCo post.) Although the SEC did not hold an open meeting
to consider the proposal, several of the Commissioners issued
statements that addressed, for the most part, not what was in the
proposal, but rather, what wasn't—standardized disclosure
requirements related to climate change. These statements allow us a
peek into an apparently heated debate among the Commissioners on
the issue of climate disclosure.
SideBar
This debate should be considered against the backdrop of
accelerating investor interest, particularly among large
institutional investors, in sustainability disclosure. This year,
sustainability—especially as viewed through the lens of
economic impact—has become a central concern among investment
managers and others. For example, in his annual letter to CEOs,
BlackRock CEO Laurence Fink
