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Republican SEC Commissioners Continue to Criticize Proposed Climate Disclosures

Last week, SEC Commissioner Peirce delivered a lengthy speech at the American Enterprise Institute, in which she extensively criticized the climate disclosure rules proposed by the SEC. Her critique deliberately extended...more

Preparation for 2022 Fiscal Year-End SEC Filings and 2023 Annual Shareholder Meetings

Public companies initiating the year-end reporting process will need to consider, and in many cases take steps to address, a number of significant developments and issues. To assist companies in this process, Mintz has...more

Energy & Sustainability Litigation Updates — November 2022

Regulatory Developments. During the past month, there have been two notable developments in connection with the SEC’s proposed climate disclosures rule — “The Enhancement and Standardization of Climate-Related Disclosures for...more

Biden Administration Proposes That Federal Contractors Must Disclose GHG Emissions

Last Thursday, the Biden Administration proposed that all federal contractors (except those receiving less than $7.5 million annually in contracts) be required to, among other things, disclose their GHG emissions....more

SEC is Rumored to Be Dropping Scope 3 GHG Emissions Disclosures from Final Climate Disclosure Rule

It has been publicly reported that the SEC is considering dropping “Scope 3” GHG emissions from the mandatory climate disclosures that were proposed last March. Such a development--a major change to the key policy initiative...more

Energy & Sustainability Litigation Updates — October 2022

Regulatory Developments Among State AGs. Over the past few weeks, various state attorneys general have either issued guidance or initiated enforcement actions in connection with ESG ratings. Specifically, among other things,...more

Potential Delay of SEC Climate Disclosures Rule Due to Reopening of Comments Period to Address Technical Issue

Last Friday, the SEC re-opened the comment period on its climate disclosures rule--"The Enhancement and Standardization of Climate-Related Disclosures for Investors"--for a period of "14 days following publication of the...more

Republican SEC Commissioner Peirce Questions Proposed SEC Rule Concerning ESG "Greenwashing"

In remarks delivered today to the SEC Investor Advisory Committee, SEC Commissioner Pierce--one of the Republican appointees to the Commission--offered a critique of the proposed SEC rule re: "greenwashing," which is the...more

SEC Chairman Gensler Re-Affirms Importance of Climate Disclosures in Senate Testimony

Today, SEC Chairman Gensler testified before the Senate Committee on Banking, Housing, and Urban Affairs. His remarks were wide-ranging, and touched upon a number of different SEC priorities--but Chairman Gensler made sure...more

Republican Senators Press Judicial Nominee to Third Circuit on ESG Issues

During the Senate Judiciary Committee's hearing on the nomination of Delaware Supreme Court Justice Montgomery-Reeves to the Third Circuit Court of Appeals, certain Republican Senators, including Grassley (R-Iowa) and Lee...more

Draft SEC Five-Year Strategic Plan Emphasizes Importance of Climate Disclosures

Recently, the SEC issued its five-year strategic plan for public comment.  This strategic plan covers a wide variety of topics, ranging from adapting to new technology to plans for increasing internal SEC workforce...more

Republican SEC Commissioners Telegraph Continued Opposition to Climate Disclosure Rules

Last week, the two Republican Commissioners of the SEC availed themselves of the opportunity presented by the ability to comment on the Financial Accounting Foundation's Strategic Plan Draft for Public Comment to again voice...more

French Regulator Calls For Regulation of Providers of ESG Ratings and Other Services

The AMF, the stock market regulator in France, recently reiterated its call for stricter regulation on a Europe-wide basis of the entities providing ESG ratings and other services. Specifically, the AMF stated that the...more

SEC Announces Disclosures and Rules Changes Intended to Combat "Greenwashing"

Today, the SEC issued two complementary press releases announcing certain proposed rules. First, the SEC announced "proposed amendments to enhance and modernize the Investment Company Act 'Names Rule'" that would "extend the...more

Organizations Taking Into Account Increased Wildfire Risk Due to Climate Change

A non-profit research group, First Street Foundation, recently released data that calculates the wildfire risk for each property in the United States (excluding Alaska and Hawaii). Notably, according to First Street...more

SEC Chairman Gensler Re-Affirms Support for Mandatory Climate Disclosures

In a speech delivered on May 6, 2022 to the Annual Conference on Financial Market Regulation, SEC Chairman Gensler again re-affirmed his support for the SEC's recent proposed mandatory climate disclosures. ...more

Political Criticism by Congressional Republicans of SEC Proposal on Mandatory Climate Disclosures

The SEC has received two comment letters from members of Congress--one from the House of Representatives and one from the Senate--criticizing its proposal for mandatory climate disclosures....more

SEC Chairman Gensler Defends Proposed Climate Disclosures

SEC Chairman Gensler delivered a set of prepared remarks at the Ceres Investor Briefing on April 12, 2022, in which he defended the SEC's newly proposed rule concerning climate disclosures. As expected, Chairman...more

SEC's Proposed Climate Disclosures Receive Support from Bank of America

According to Paul Donofrio, the head of sustainability at Bank of America, the SEC's proposal for climate disclosures is "constructive and headed in the right direction." Donofrio voiced further support for the SEC's...more

Senator Manchin Criticizes Proposed SEC Climate Disclosures

Senator Joe Manchin (D-WV) has issued a public letter criticizing the SEC's recent proposal for mandatory climate disclosures. Specifically, Manchin questions the need for such a rule based on the fact that a majority of...more

SEC Announces ESG as Examination Priority

Following-up on the extensive new mandatory climate disclosures the SEC issued last week, the SEC has now announced that "ESG" will be the second enforcement priority of its examination division during 2022. Specifically,...more

A Brief Summary of the SEC’s Proposed Climate-Related Rules

On March 21, 2022, the Securities and Exchange Commission (“SEC”) unveiled its long-anticipated proposed rules on climate disclosures, entitled “The Enhancement and Standardization of Climate-Related Disclosures for...more

SEC Issues Proposed Regulation on Mandatory Climate Disclosures

On March 21, 2022, the SEC finally issued a proposed rule on mandatory climate disclosures. This proposed rule has been expected for some time--it was widely anticipated to be a centerpiece of the Biden Administration's...more

Raskin Nomination for Federal Reserve Torpedoed by Conservative Objections to Potential Climate Regulations

Yesterday, Sarah Bloom Raskin, who had previously served as a Federal Reserve governor and deputy Treasury secretary during the Obama administration, withdrew her nomination to be the Federal Reserve's vice chair of...more

SEC to Propose Rules Concerning Mandatory Climate Change Disclosures on March 21

According to media reports, the SEC has announced that it will "propose rules mandating disclosure from publicly traded companies about climate change and associated risks" on March 21st....more

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