New Insights into the SEC’s Climate Change Disclosure Rulemaking

On August 6, 2021, Cravath prepared for its clients a memo entitled “New Insights into the SEC’s Climate Change Disclosure Rulemaking,” which summarized the July 28, 2021 speech given by Securities and Exchange Commission (“SEC”) Chair Gary Gensler about the SEC’s climate change disclosure rulemaking process. The memo outlined six key takeaways from the speech, including the location of disclosure, scope of quantitative disclosures, relationship with third‑party ESG reporting standards, rules applicable to funds, significant omissions from the speech and timing for the SEC’s rulemaking. The memo also discussed the lessons the remarks provide for companies seeking to prepare for a future SEC climate change disclosure regime.

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