This blog explains that the SEC’s proposed climate risk disclosure rule is not novel or unique, but well-centered within the constellation of prior SEC regulations.
Bridget PalsJuly 15, 2022
These comments from 15 climate scientists and experts discuss the science of climate change detection and attribution—the body of research that helps to characterize the role of human activity in climate change—as well as how models are used to develop climate change projections. The goal of these comments is to…
This letter focuses on two aspects of the justification provided by the Securities and Exchange Commission (SEC) for its proposed rule on climate-related disclosures. First, the letter evaluates the Commission’s rationale for using prescriptive—as opposed to principles-based—disclosure requirements for climate-related financial risk. Second, the letter evaluates the Commission’s rationale for…
In response to the Securities and Exchange Commission's proposed rule on climate-related disclosures, this letter commends the SEC for conducting an economic analysis that is consistent with relevant case law, and suggests some revisions that would provide additional context and support for the final analysis.
In her dissent from the Securities and Exchange Commission's proposed rule on climate-related disclosures, Commissioner Peirce describes the SEC as “discover in a long-extant statute an unheralded power to regulate ‘a significant portion of the American economy’” and impermissibly transforming its regulatory role into that of a “Securities and Environment…
These comments to the Federal Deposit Insurance Corporation (FDIC) support the FDIC's draft principles on banks' management of climate-related financial risks, and offer recommendations for the FDIC as it continues building on these principles with more detailed guidance. The comments recommend that the FDIC consider: (1) providing more detail on…
This blog describes how the Securities and Exchange Commission’s proposal on climate-related disclosures would address key investment information gaps through comparable, specific, and decision-useful disclosures. It notes five reasons for stakeholders to weigh in through the public comment process.
Gabriel MalekApril 21, 2022
This blog explains why the Securities and Exchange Commission's proposed climate risk disclosure standards, which were designed to meet the needs of investors, will also convey important benefits to businesses.
Maren TaylorApril 18, 2022
In this webinar EDF+ Business Project Manager Gabriel Malek moderated a conversation with Michael Panfil, Lead Counsel and Director of Climate Risk Strategies of EDF, Wendy Cromwell, Head of Sustainable Investing for Wellington Management, and Fitzann Reid, Deputy General Counsel with Engine No. 1, on key elements of the Securities…
Gabriel Malek, Michael Panfil and OthersApril 7, 2022