Further to last week’s report: “SEC Climate Disclosure Comment Letters,” KPMG’s analysis of 150 comment letters across industries and respondent types in response to the SEC’s climate disclosure proposal unsurprisingly revealed varying levels of support for different aspects of the proposal.
While the comment letters analyzed by the firm are not billed as a representative sampling, the big picture observations are nonetheless interesting and informative. Most notably, regardless of varying support levels, very few of the key provisions of the proposed rule highlighted in the report garnered support from even a substantial minority of commenters on an “as is” basis (i.e., without changes). On the proposed financial statement disclosures in particular, just 13% of respondents supported inclusion of the climate-related data in the audited financials, as shown here:
More than 60% of the 61 respondents in the sample who responded to the SEC’s request for comment on a potential alternative global reporting framework expressed support for the forthcoming ISSB standards for foreign private issuers or all issuers (including domestic issuers).
See the Society’s comment letter in response to the proposal here and additional comment letters here.
This post first appeared in the weekly Society Alert!