• Posts by Susan S. Failla
    Posts by Susan S. Failla
    Partner

    Susan is co-head of the firm’s Capital Markets practice. She has led capital markets transactions totaling over $150 billion for companies in the consumer products, energy, information services and financial services ...

Time 5 Minute Read

On September 22, 2021, the Division of Corporation Finance (Division) of the Securities and Exchange Commission (SEC) issued a sample comment letter to highlight its increased focus on climate change-related disclosures or the absence of such disclosures in issuer filings under the Securities Act and the Exchange Act. This sample comment letter follows a recent increase in climate-related comments the Division has issued during the disclosure review process, and many of the sample comments appear to be derived from actual comment letters issued in 2021. The sample is consistent with the SEC’s 2010 Guidance Regarding Disclosure Related to Climate Change, which does not mandate specific, line item climate change-related disclosures, but instead takes a principles-based approach.

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