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OCC, FRB, and FDIC Finalize Joint Principles for Climate-Related Financial Risk Management

Guidance for the largest US financial institutions is intended to promote climate risk management consistent with general safety and soundness practices. On October 30, 2023, the three US federal bank regulatory agencies...more

California’s New VC Diversity Reporting Law Aims to Increase Transparency

Venture capital firms should begin planning now for compliance to avoid monetary penalties or court action. California Governor Gavin Newsom signed Senate Bill No. 54 (SB 54) into law on October 8, 2023. The bill is...more

Transparency Is Key for PE Amid Greenbashing Risk

As ESG statements fall under increasing scrutiny, sponsors should aim for consistent and accurate messaging, as well as robust ESG strategies. Regulatory drivers and stakeholder demands have put environmental, social,...more

SEC Adopts Changes to Names Rule for Registered Funds

The amendments aim to modernize the Names Rule and promote investor protection objectives by ensuring that a fund’s portfolio of holdings aligns with its name. The US Securities and Exchange Commission (the SEC or the...more

Timely ESG Updates for Public Companies Preparing Annual Reports

Developments span the climate disclosure landscape, risk factor disclosure, and diversity-related efforts. In advance of the annual shareholder proposal and annual reporting preparation season, we believe that a number of...more

California Passes GHG Emissions Reporting and Climate-Related Financial Risk Legislation

Governor Newsom has committed to signing into law two bills that would require certain companies that do business in California to disclose their GHG emissions and climate-related financial risks. In January 2023,...more

TNFD Publishes Finalized Recommendations for Nature Related Disclosures

On September 18, 2023, the Taskforce on Nature-related Financial Disclosures (TNFD) published recommendations for organizations’ assessment, management, and disclosure of nature-related issues (the Recommendations). These...more

The PROVE IT Act: Proposed US Legislation Aiming to Collect Product-Level GHG Data Could Have Wider Implications

Data collected under the PROVE IT Act would measure the carbon emissions of certain goods in the US and other nations. On June 7, 2023, US Senators Chris Coons and Kevin Cramer introduced the bipartisan Providing...more

ISSB Issues Global Sustainability Disclosure Standards

On June 26, 2023, the International Sustainability Standards Board (ISSB) released its first two standards for sustainability disclosures, which are designed to facilitate the disclosure of sustainability-related information...more

Florida Law to Restrict the Use of Certain ESG Factors by Asset Managers and Financial Institutions

The legislation mirrors anti-“industry boycott” legislation introduced or passed in other US states and provides more explicit rubrics of prohibited factors. On May 5, 2023, Florida Governor Ron DeSantis signed into law...more

ESG Initiatives Face Increased Pressure From Potential Antitrust Challenges

A recent letter from 21 state Attorneys General to various asset managers demonstrates a focus on using antitrust and unfair competition laws to oppose ESG efforts. Key Points: ..ESG investing initiatives are not...more

Sustainability-Linked Bond Issuers Miss Sustainability Targets: 10 Takeaways

Issuers should consider the ambitiousness of their sustainability targets, any challenges in achieving the targets on schedule, and how they will prove their progress. The global market for sustainability-linked bonds ...more

DOL Final Rule on ESG Factors to Take Effect February 1, 2023

The Final Rule clarifies the application of ERISA’s fiduciary duties of prudence and loyalty to the selection of plan investments that incorporate ESG goals. On November 22, 2022, the US Department of Labor (DOL) released a...more

COP15’s Global Biodiversity Framework and the Rising Focus on Nature - What Businesses Can Expect

The Framework looks to guide global action on biodiversity, ecosystems, and other aspects of natural capital through 2030 and beyond. Key Points: ..The Global Biodiversity Framework adopted at COP15 to the Convention on...more

NYDFS Proposes Guidance on Climate Change Risk Management

The Guidance would increase expectations for regulated financial institutions to identify, measure, monitor, and control climate-related financial risks. For the past few years, the New York State Department of Financial...more

Updated Timeline for ESG-Related Actions From SEC Under RegFlex Agenda

​​​​​​​On January 4, 2023, the Office of Information and Regulatory Affairs released the Fall 2022 Regulatory Flexibility Agenda. The agenda includes several updates to the Securities and Exchange Commission’s plans for...more

ESG Insights: 10 Things That Should Be Top of Mind in 2023

Navigating a global patchwork of ESG regulation and enforcement while preparing for greenwashing claims and other ESG litigation will likely be among the main concerns for companies in 2023. Both anticipated and less...more

FTC Seeks Public Comments on Green Guides as Part of 10-Year Review Cycle

The updated Green Guides will likely impact legal liability for environmental marketing claims in the years to come. On December 20, 2022, the Federal Trade Commission (FTC) published a notice (hereinafter, the 2022...more

US Government Proposes Climate-Related Requirements for Government Contractors

Major federal suppliers would need to perform certain climate-related actions, resulting in potential knock-on implications, expectations, and risks. Key Points: ..The federal government’s proposed regulations would...more

Federal Reserve Proposes Climate Risk Guidance for Large Financial Institutions

The guiding principles are similar to related proposals from other banking regulators, but will require further clarification through the comment process. On December 2, 2022, the Board of Governors of the Federal...more

COP27: Overview and Key Takeaways

Establishment of the loss and damage fund and development in Article 6 of the Paris Agreement were among the major developments in this year’s conference. On November 20, 2022, the 27th annual Conference of Parties...more

The Future of Human Rights Due Diligence: UNGPs and the Draft Treaty on Business and Human Rights

Human rights due diligence standards are being negotiated at the international level, which may complement or complicate national and regional regulations. Latham & Watkins is pleased to introduce a series of Clients...more

Updates From Week One of COP27: Article 6 Negotiations and US Announcements

Extensive negotiations focused on finalizing the details of a “rulebook” for an international carbon market under Article 6 of the Paris Agreement. The 27th annual Conference of Parties (COP27) of the United Nations...more

Voluntary ESG “Materiality” Assessments - Legal Considerations and Dos and Don’ts

This Client Alert probes the ESG “materiality assessment” process, why it is a misnomer, when and how the assessment can be conducted, and legal and practical tips for conducting the assessment. Companies have been...more

ECB and IMF Call to Avoid Fragmentation in Global ESG-Related Disclosure Requirements

The call highlights the challenges in developing alignment between global ESG reporting standards. The European Central Bank (ECB) and the International Monetary Fund (IMF), two of the world’s leading public financial...more

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