In September, an illustrative comment letter provided example questions that the SEC staff is posing to companies regarding climate-related disclosures. As the staff continues to probe disclosures, we recommend using the example comment letter to help assess whether the appropriate disclosures are included in 2021 year-end filings.
Relevance of the sample letter to 2021 year-end filings
“Although the sample comment letter relates to climate disclosures, it’s a timely reminder that the SEC staff is focused on ESG more broadly.
I encourage all issuers to think about whether they are disclosing all material ESG-related information – for example, related to human capital and cybersecurity risk governance – that might be necessary to ensure their filings are not misleading.”
— Timothy Brown, Partner, SEC & Regulatory Reporting
The sample letter shows extensive inquiries
SEC climate-related disclosure proposals