In September 2021, an illustrative comment letter provided example comments that the SEC staff is sending to companies regarding climate-related disclosures. More than a year later, the staff continues to probe disclosures. Staff frequently pushes issuers to provide a quantitative analysis supporting claims that the disclosure is immaterial. If you haven’t revisited your current disclosures using the example comment letter, we recommend doing it now.
More than a year in, we are seeing more focus by staff
“I believe that the SEC staff questioning of filings will really begin to bite. Companies are getting closer to their commitment dates – an example might be, say, a 50% emissions reduction by 2030 – so that means the financial reporting considerations start to become material. My advice would be, do your homework now – don’t let yourself get caught off-guard.”
— Julie Santoro, Partner, Department of Professional Practice
A reminder of what’s in the sample letter
The SEC’s climate proposal