In February 2010, the United States Securities and Exchange
Commission (SEC) released its Interpretive Release on Climate
Change Disclosure (SEC Release). Subsequently, on April 1, 2010,
ASTM International released E2718-10: Standard Guide for
Financial Disclosures Attributed to Climate Change (Guide).
The Guide is intended for voluntary use by reporting entities.
I. Purpose of the Guide
The purpose of the Guide is to assist publicly-traded companies
in (1) identifying material financial impacts attributable to
climate change that warrant disclosure in their financial
statements, and (2) determining the appropriate content of the
disclosure. The Guide states that it is designed to give
instructions "consistent with good commercial and customary
practice" for climate-change related disclosures accompanying
audited and unaudited financial statements, and to encourage
"consistent and comprehensive" disclosure of financial
impacts attributed to climate change. The