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Keeping you in-the-know on environmental, social and governance developments

You may have heard that the SEC has reopened the public comment period on a number of regulatory proposals. My colleague John Jenkins wrote about this over on

On Friday, the SEC announced that a ‘technological error’ dating back to as early as June 2021 has prompted it to reopen the comment period on 11 rulemaking proposals and one request for comment… According to the SEC’s order, the comment periods reopened beginning on October 7, 2022, and will close 14 days after the date of publication of the order in the Federal Register.

Yes, the climate disclosure proposal is one of those affected.

What This Means

Renee Jones, the Director of the SEC’s Division of Corporation Finance said Day 1 of the 2022 Proxy Disclosure Conference that over 4,000 unique substantive letters have already been received and reviewed. Liz summed up what we are hearing about the potential impact of the latest comment period extension:

Views differ on whether that will affect timing for a final rule, but the overall sense is ‘probably not by much.’ It is likely that most of the letters that got missed were form letters that probably don’t offer anything new in terms of substance. Those who submitted significant comments with unique points probably checked the SEC comments page and confirmed that their letter was posted/received by the original or first extended deadline, so it’s unlikely that letters like that got missed. Even so, the SEC Staff must take extra time to go through to make sure they’ve accounted for everything.

It would be prudent to continue along your current path and timing for preparing for an SEC climate disclosure based on the proposal. The final panel of Tuesday’s 1st Annual Practical ESG Conference and the first panel of today’s 2022 Proxy Disclosure Conference offer practical guidance to those working toward their disclosure. And don’t forget that members have exclusive access to our 58-page annotated sample disclosure based on the proposal (available as a Guidebook).

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The Editor

Lawrence Heim has been practicing in the field of ESG management for almost 40 years. He began his career as a legal assistant in the Environmental Practice of Vinson & Elkins working for a partner who is nationally recognized and an adjunct professor of environmental law at the University of Texas Law School. He moved into technical environmental consulting with ENSR Consulting & Engineering at the height of environmental regulatory development, working across a range of disciplines. He was one… View Profile