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SEC Continues Issuing Climate Comment Letters

Jan 9 2024 #climate, #compliance, #esg, #investors, #supply-chain

Over on TheCorporateCounsel.net, Meredith blogged on updates concerning new climate related comment letters the SEC Staff sent to more than 12 companies in the past three months. Some of the company responses include:

Estee Lauder’s first and second response
Eli Lilly’s first, second and third response
Oracle’s first and second response
PENN Entertainment’s first and second response

She concludes: “For companies in annual reporting season, know that SEC comments on climate disclosures continue apace, and the Staff is not waiting on final rules. In terms of what to expect, the newest letters seem consistent with Corp Fin’s sample comment letter.” This is another reminder that, as I wrote in November, the SEC is clearly looking at ESG matters, materiality and disclosures through the lens of long standing traditional securities regulations.

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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

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