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ARTICLE · 28 SEPTEMBER 2021

SEC Issues Sample Letter On Climate Change Disclosures

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For many or most issuers, the disclosure as to the risks of legislative change is likely to be more significant than the risks as to the tangible effects of climate change.

United StatesCorporate/Commercial Law
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The SEC Division of Corporation Finance (the "Division") provided companies with an example of a letter "containing sample comments that the Division may issue to companies regarding their climate-related disclosure or the absence of such disclosure."

The Division reminded companies of the following climate change-related disclosures that may be required by the SEC's 2010 Climate Change Guidance:

  • the effect of proposed or current legislation, rules and international agreements as to climate change;
  • the indirect impact of rules or the direction of a relevant industry; and
  • the tangible effects of climate change.

In its sample letter, the Division included, among others, the following matters about which it may inquire:

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