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Agency FilingRisk Management

Comments to FEMA on Proposed Rule to Modify the Standard Flood Insurance Policy Under the National Flood Insurance Program

Organizations Involved: Policy Integrity Abstract The Federal Emergency Management Agency (FEMA) proposed a rule to modify the standard flood insurance policy under the National Flood Insurance Program by creating a new “Homeowner Flood Form,” which applies specifically to homeowners of single-family homes and owners of buildings with one-to-four units. The…
Dena Adler, Bridget Pals and Jason Schwartz
May 31, 2024
Agency FilingEnergy RegulationFederal Energy Regulation

Comments to DOE on Voluntary Carbon Dioxide Removal Purchasing Challenge (Policy Integrity)

Organizations Involved: Policy Integrity Abstract In March 2024, the Department of Energy (DOE) published a Notice of Intent Regarding Launching a Voluntary Carbon Dioxide Removal Purchasing Challenge (Purchasing Challenge). To participate in the Purchasing Challenge, organizations must disclose to DOE several details about each associated carbon dioxide removal (CDR) credit,…
Donald Goodson, Jason Schwartz, Erin Shortell and Derek Sylvan
May 15, 2024
Event/ConferenceFinancial Regulation

Webinar: The Potential Role of Federal Regulation in Voluntary Carbon Markets

Organizations Involved: Institute for Policy Integrity; Initiative on Climate Risk and Resilience Law Source: Institute for Policy Integrity; Initiative on Climate Risk and Resilience Law Abstract In partnership with the Initiative on Climate Risk and Resilience Law, the Institute for Policy Integrity will host a webinar to explore the potential…
Erin Shortell and Donald Goodson
April 4, 2024
Blog/News ArticleFinancial DisclosureRegulatory Activities

The SEC’s Final Climate Disclosure Rule: Interrogating Preemption and Coherence with Other Domestic Regimes

Organizations Involved: Sabin Center Source: Climate Law Abstract This blog explores preemption questions in the context of the SEC's new climate rule and other domestic disclosure frameworks: California’s climate-disclosure laws and the Environmental Protection Agency (EPA)’s GHG emissions reporting regime. It is the third in a series of three blogs that address specific…
Chloe Field and Cynthia Hanawalt
March 29, 2024
Agency FilingFinancial DisclosureFinancial RegulationRegulatory Activities

Amicus Brief on Major Questions Doctrine in Fifth Circuit Case Over DOL’s 2022 Investment Duties Rule

The Institute for Policy Integrity filed an amicus brief in the Fifth Circuit arguing that the lower court correctly concluded the Department of Labor's 2022 Investment Duties Rule does not trigger the major questions doctrine because past regulatory practice demonstrated the case was not extraordinary enough to trigger the doctrine.…
Donald Goodson and Jessie Arnell
March 26, 2024
Blog/News ArticleFinancial DisclosureRegulatory Activities

The SEC’s Final Climate Disclosure Rule: Pathways for Improving the Floor

Organizations Involved: Sabin Center Source: Climate Law Abstract This post addresses two aspects of SEC’s climate rulemaking process: should the rule have been re-proposed, and, more importantly, how might the SEC update and strengthen the rule going forward. It is the second in a series of three blogs that address…
Chloe Field and Cynthia Hanawalt
March 20, 2024
Adaptation as Risk ManagementFinancial DisclosureFinancial RegulationRegulatory ActivitiesReportRisk Management

An Investor Guide to the SEC Rule on Climate-Related Disclosures

On March 6, 2024, the Securities and Exchange Commission (SEC) issued a final rule for “The Enhancement and Standardization of Climate-Related Disclosures for Investors.” The rule requires covered companies to disclose certain types of climate-related information, bringing climate risk disclosure on par with other financial reporting requirements for publicly traded…
Stephanie Jones, Andrew Howell, Guillaume Morauw, Marie Li, Maximilian Schreck and Gabrielle Stephens
March 18, 2024
Blog/News ArticleFinancial DisclosureRegulatory Activities

The SEC’s Final Climate Disclosure Rule: Key Requirements, and the Materiality Threshold

Organizations Involved: Sabin Center Source: Climate Law Abstract Nearly two years and 24,000 public comments after its proposal, the Securities and Exchange Commission (SEC) released its final climate disclosure rule March 6th, formally titled “The Enhancement and Standardization of Climate-Related Disclosures for Investors.” This blog offers a summary of the final…
Chloe Field and Cynthia Hanawalt
March 11, 2024
Agency FilingFinancial DisclosureFinancial RegulationRegulatory Activities

Comments to CFTC on Proposed Guidance on Voluntary Carbon Credit Derivatives (Policy Integrity)

Organizations Involved: Institute for Policy Integrity Source: Institute for Policy Integrity Abstract In December 2023, the Commodity Futures Trading Commission (CFTC) proposed guidance that identifies key features of high-integrity voluntary carbon credits (VCCs) for exchanges that list certain VCC derivatives. The Institute for Policy Integrity submitted comments that highlight additional…
Donald Goodson, Jason Schwartz and Erin Shortell
February 16, 2024