Yesterday, the Society submitted this comment letter to the SEC explaining why the SEC’s proposed climate disclosure rule should be characterized as a “major rule” for purposes of the Small Business Regulatory Enforcement Fairness Act of 1996, which is one of the questions posed in the proposing release that very few commenters addressed. As discussed in the letter, a major rule designation offers important procedural protections for companies. The letter supplements our initial comment letter submitted in June and supplemental letter submitted in September.
The Society thanks Society member and Sullivan & Cromwell’s June Hu for her guidance and participation on this letter.
Access additional resources on our Climate Risk & Disclosure page.
This post first appeared in the weekly Society Alert!