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An educational service that provides practical guidance on legal issues involving public and private mergers & acquisitions, joint ventures, private equity – and much more.


The “one stop” resource for information about responsible executive compensation practices & disclosure.

Widely recognized as the premier online research platform providing practical guidance on issues involving Section 16 of the Securities Exchange Act of 1934 and all of its related rules.


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

We recently featured Shari Littan on a joint podcast on the new COSO guidance document on Internal Controls over Sustainability Reporting (ICSR). Shari was one of the primary authors of the document. Last week, she spent time on another podcast with Ropes & Gray’s Michael Littenberg (also a member of our Advisory Board) on ICSR, going into more detail along with another primary author Doug Hileman.

One point Shari made in her comments with Michael:

“… the SEC has started to issue comment letters on company filings where the Form 10-K or financial reports are not aligned with sustainability or ESG information in other non-SEC reporting. One good thing about a good control system, governance and oversight, is to make sure that information aligns, so that internal groups are speaking cohesively and working to make sure the company is not saying two or three different things in different places. The analysts also will pick up on that.”

Shari is spot on with that insight. We’ve blogged before on SEC’s latest round of climate and ESG-focused comment letters issued from July 1, 2021 to March 31, 2023. One of the nine topics identified by the SEC in its sample letter is internal controls over data and disclosures between the level of disclosure provided in corporate sustainability reports and in SEC filings.

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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