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CARB Will Not Fully Enforce California’s Climate Corporate Data Accountability Act in 2026

CARB will not penalize reporting entities for incomplete Scope 1 and 2 emissions disclosures under SB 253, irritating lawmakers and raising the specter of oversight hearings....more

FRB Issues Report on Climate Scenario Analysis Pilot

With regulators keeping close watch, the results underscore the need for ongoing climate risk management investment and adaptation within the financial sector. On May 9, 2024, the Board of Governors of the Federal...more

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

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

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

Disclosing Climate-Related Risks and Metrics Under the SEC’s Proposed Rule

What the proposed rule would mean for registrants and their filings with the SEC. The US Securities and Exchange Commission’s proposed climate disclosure rule, approved by a 3–1 vote on March 21, 2022, is the agency’s...more

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