On July 15, the Society submitted this comment letter in support of the SEC's proposal to rescind its climate-related disclosure rule adopted in March 2024.
Consistent with the Society's prior comment letters on the proposed rule (here, here, and here), the Society supports rescission of the rule in its entirety and encourages the Commission to continue relying on a registrant-specific, materiality-based disclosure framework that elicits information material to investors based on each registrant's particular facts and circumstances. The letter also recommends that the Commission update and enhance its 2010 Guidance Regarding Disclosure Related to Climate Change to assist registrants in applying existing disclosure requirements to climate-related matters rather than maintain prescriptive climate-specific disclosure mandates.
This post first appeared in the weekly Society Alert!