Key Takeaways from the SEC Sample Comment Letter on Climate Change Disclosure

Practical ESG | September.27.2021

On September 22, 2021, the SEC's Division of Corporation Finance published a letter containing sample comments that the Division may issue to companies regarding climate change disclosure. The first comment addresses the issues that can arise when companies provide more expansive disclosure in their corporate social responsibility reports than in their SEC filings. In this guest post for Practical ESG, Orrick's J.T. Ho and Ashley Walter analyze the SEC's letter and provide practical tips for companies in the process of preparing their climate change disclosures.