US SEC Division Of Corporation Finance Publishes Sample Letter To Companies Regarding Climate Change Disclosures – Corporate/Commercial Law


United States: &#13
US SEC Division Of Company Finance Publishes Sample Letter To Companies Relating to Local climate Change Disclosures&#13


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The US Securities and Exchange Commission’s&#13
(SEC) Division of Corporation Finance&#13
(Division) revealed a sample letter with responses&#13
that the Team intends to concern to community companies relating to their&#13
local climate transform disclosures-or lack thereof-in SEC filings. As&#13
defined in a prior Mayer Brown article, Commissioner Lee, when&#13
she was Acting Chair of the SEC previously this year, directed the&#13
Personnel to raise its attention on the ways in which community&#13
providers implement the SEC’s 2010 Guidance Pertaining to&#13
Disclosure Associated to Local climate Adjust, which offers direction to&#13
providers about the SEC principles that may perhaps involve disclosure about&#13
climate modify, regardless of the fact that climate modify is not&#13
explicitly referenced in the existing procedures.

The SEC’s disclosure necessities are mostly&#13
ideas-based mostly and may perhaps have to have diverse information and facts from&#13
diverse companies, which includes local climate change-linked&#13

The sample opinions could utilize to numerous companies, and ask for&#13
evaluation, as nicely as disclosure, to the extent substance. As an&#13
illustration, just one comment states:

“We observe that you furnished&#13
far more expansive disclosure in your company social obligation&#13
report (CSR report) than you delivered in your SEC filings. Make sure you&#13
advise us what thing to consider you gave to supplying the identical form of&#13
local weather-linked disclosure in your SEC filings as you presented in&#13
your CSR report.”

When the SEC’s rule record suggests that a weather improve&#13
disclosure rulemaking is on the near-phrase agenda, no new policies have&#13
been adopted or proposed yet. Accordingly, the sample remarks are&#13
competent to demonstrate that revised disclosure is only demanded to&#13
the extent material. That reported, corporations need to be prepared to&#13
offer a materiality analysis in response to SEC responses.

Regardless of whether or not corporations obtain local weather adjust-connected&#13
feedback from the Workers, they should re-browse the 2010 Assistance&#13
Relating to Disclosure Related to Local climate Modify and examine irrespective of whether&#13
any of the topics are applicable. Businesses need to also ensure that&#13
they have effective disclosure controls and methods in position to&#13
facilitate disclosure of material local climate alter information in&#13
their SEC filings.

The Division’s sample letter can be discovered listed here, and the SEC’s 2010 Assistance&#13
Concerning Disclosure Relevant to Local climate Alter can be found right here.

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Mayer Brown report gives facts and reviews on legal&#13
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