“A good start": SEC releases long-awaited climate risk disclosure proposals
March 23, 2022, Global Banking Regulation Review
Mellissa Duru Campbell and David Martin spoke to Global Banking Regulation Review about the SEC’s climate disclosure proposal that for the first time would be required to have some of their carbon emissions audited and included in regulatory filings, including requirements related to scope 3 emissions, scenario analysis, and transition plans.
Mellissa believed that the proposals are a “good start’ to catch up with regulatory trends in the rest of the world.” She continued, stating, “In terms of the scope of what is covered, there is a little bit more granularity in the international comparable regulatory frameworks. One wouldn't expect to have complete alignment between U.S. disclosure standards or largely U.S. companies versus international, but to the extent that there is some alignment on the most material items – and that seems to be the case, even if it’s on a high level – that seems to be a good start.”
Mellissa noted the “relatively short” 60-day comment period attached to the proposal, which Mellissa suggested may be intended to ensure that there is engagement on controversial issues “in a way that has, or at least opens up the possibility of, those issues being wrapped up within a reasonable amount of time”.
David surmised that, “It's going to be a trial-and-error process and I think this is clear enough to get everybody started, but I can't say that there won't be plenty of comment letters by the staff saying, say more or you didn't say this.” David added, “It wouldn't be the first time that a proposed rule gets adopted, and then they fuss with the safe harbor, or fuss with the timing of it all.”
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