Further to our recent report: “Heads Up! SEC Staff Querying Companies on Climate Disclosures,” in “SEC Staff Comment Letters Continue to Seek Enhanced Climate-Related Disclosures,” WilmerHale summarizes the four main comment themes represented among Form 10-K comment letters issued to more than a dozen companies in August and September 2023 about their climate disclosures and describes how companies explained their determinations that the risks or information at issue was not material.
This post first appeared in the weekly Society Alert!