“A good start": SEC releases long-awaited climate risk disclosure proposals

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.

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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