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ARTICLE · 25 SEPTEMBER 2021

SEC Shines Spotlight On Climate Change In Sample Comment Letter

Bryan Cave Leighton Paisner
Bryan Cave Leighton Paisner
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Bryan Cave Leighton Paisner

Bryan Cave Leighton Paisner

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As discussed in our March 4, 2021 and March 17, 2021 posts, Allison Herren Lee, then the Acting Chair of the SEC, previously issued a Public Statement and delivered a speech...

United StatesCorporate/Commercial Law

As discussed in our March 4, 2021 and March 17, 2021 posts, Allison Herren Lee, then the Acting Chair of the SEC, previously issued a Public Statement and delivered a speech announcing the SEC's enhanced focus on climate-related disclosures. Yesterday, the SEC's Division of Corporation Finance issued a sample comment letter to provide additional guidance on the application of its rules to climate change, including the following topics covered in the SEC's 2010 climate change guidance:

  • The impact of pending or existing climate-change related legislation, regulations and international accords
  • The indirect consequences of regulation or business trends
  • The physical impacts of climate change

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