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Financial Disclosure

Agency FilingFinancial DisclosureFinancial Regulation

Comments to the SEC from Climate Scientists/Experts on Proposed Rule on Climate-Related Disclosures

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…
Michael Burger, Jeffrey Fralick, Radley Horton, Romany Webb and Others
June 17, 2022
Agency FilingFinancial DisclosureFinancial Regulation

Comments to the SEC on Reasoned Explanation for Its Proposed Rule on Climate-Related Disclosures

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…
Lance Bowman, Jack Lienke, Bridget Pals, Alex Song, Michael Panfil, Noha Haggag, Stephanie Jones, Madison Condon and Others
June 17, 2022
Agency FilingFinancial DisclosureFinancial Regulation

Comments to the SEC on Economic Analysis for Its Proposed Rule on Climate-Related Disclosures

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.
Lance Bowman, Jack Lienke, Bridget Pals, Alex Song, Michael Panfil, Noha Haggag, Stephanie Jones and Madison Condon
June 17, 2022
Agency FilingFinancial DisclosureFinancial Regulation

Comments to the SEC on Regulatory Precedents for Its Proposed Rule on Climate-Related Disclosures

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…
Lance Bowman, Jack Lienke, Bridget Pals, Alex Song, Michael Panfil, Noha Haggag, Stephanie Jones and Madison Condon
June 17, 2022
Adaptation as Risk ManagementAgency FilingEnvironmental JusticeFinancial DisclosureFinancial RegulationRegulatory ActivitiesRisk Management

Comments to the FDIC on Principles for Climate-Related Financial Risk Management for Large Financial Institutions

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…
Stephanie Jones, Michael Panfil, Jack Lienke and Bridget Pals
June 3, 2022
Event/ConferenceFinancial DisclosureFinancial Regulation

Unpacking the Proposed SEC Rule on Climate Risk Disclosure

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 Others
April 7, 2022