“The SEC Focuses on Climate Change in Latest Round of Comment Letters” from Audit Analytics summarizes statistics and common themes in climate change-related comment letters received by nine companies. Most notably, the post affirms the fact that the SEC is scrutinizing climate change disclosures in SEC filings in comparison to disclosures made in company sustainability reports and on corporate websites, and is holding companies accountable for the differences by, for example, requesting data to support quantitative and qualitative materiality assessments. Company responses to SEC comment letters disclosed to date reportedly tend to assert the absence of qualitative or quantitative materiality, accompanied by the requisite support.
See “SEC Asks Companies for Rationales Behind Disclosures of Climate Risks” and additional information & resources on our Climate Risk & Disclosure page.
This post first appeared in the weekly Society Alert!