While the SEC is in the midst of crafting new rules on climate change-related disclosures, it is also stepping up its review of companies’ compliance with existing SEC climate change guidance that may require disclosures related to climate risk and opportunities. The SEC has reportedly issued in recent weeks several comment letters exclusively related to climate change disclosures in Form 10-K filings, and then, on September 22, 2021, the SEC’s Division of Corporation Finance published a sample letter highlighting comments that it may issue to companies regarding their climate change disclosures—or the absence of such disclosures—in SEC filings.
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