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ARTICLE · 20 FEBRUARY 2025

A Quantitative Analysis Of Comment Letters Issued By The SEC Concerning Climate Change Disclosures: Further Developments

Mintz, Levin, Cohn, Ferris, Glovsky and Popeo, P.C.
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In June 2023, Mintz published an article entitled "A Quantitative Analysis of Comment Letters Issued by the SEC Concerning Climate Change Disclosures" (the June 2023 Article), which analyzed the comment letters related to climate change ...

United StatesEnvironment
Jacob Hupart
Jacob Hupart
Anne L. Bruno
Anne L. Bruno
Elana Lerner Brockmann
Elana Lerner Brockmann
Rebecca Horton
Rebecca Horton
Brooke Siegal
Brooke Siegal
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I. Introduction

In June 2023, Mintz published an article entitled "A Quantitative Analysis of Comment Letters Issued by the SEC Concerning Climate Change Disclosures" (the June 2023 Article), which analyzed the comment letters related to climate change issued by the US Securities and Exchange Commission (SEC) to individual reporting entities, between July 1, 2021 and March 31, 2023. That article sought to explore the practical impact of the SEC's September 2021 "Sample Letter to Companies Regarding Climate Change Disclosures" (Sample Letter), which identified nine (9) climate-related topics on which the SEC planned to focus, and to provide analysis and insight into the various climate-related comments issued by the SEC and the targets of that regulatory focus.

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