SEC Staff Highlights Comments On Climate Change Disclosure

The Division of Corporation Finance of the U.S. Securities and Exchange Commission recently published a sample letter to companies providing illustrative comments that the Division of Corporation Finance may issue to companies regarding their climate-related disclosure, or the absence of climate-related disclosure¹ (the "Sample Letter").

This action is the latest in a series of developments demonstrating the SEC's focus on climate disclosure by public companies.

• The SEC continues to focus on and spotlight climate change and ESG-related disclosure obligations under the federal securities laws.
• The SEC may be working to update its 2010 guidance on climate change disclosure and the staff of the Division of Corporation Finance has sent out letters to public companies providing comments on climate-related disclosure or the lack of such disclosure in SEC reports.