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EPA to Announce Proposed Regulation To Control GHG Emissions From Power Plants

It has been publicly reported that the Biden Administration's EPA will shortly "announce limits on greenhouse gas emissions from power plants that could compel them to capture the pollution from their smokestacks."  In...more

SEC Commissioner Voices Strong Support for Proposed SEC Climate Disclosure Rule and Related Proposed ESG Disclosure Rules

SEC Commissioner Lizarraga, one of the recent Democratic appointees to the Securities & Exchange Commission, delivered a speech on April 18 at the annual public policy symposium of the North American Securities Administrators...more

SEC Chairman Gensler Reinforces Commitment of SEC to Climate Disclosures

Last week, SEC Chairman Gensler testified before the House Committee on Financial Services.  As part of his talk, which addressed a number of topics--including, inter alia, artificial intelligence and crypto--Chairman Gensler...more

Energy & Sustainability Litigation Updates — March 2023

State and Local ESG Regulation. Despite recent public statements by notable Republican federal officials, including an SEC Commissioner, that have expressed considerable skepticism towards the SEC’s proposed ESG...more

President Biden Issues First Veto to Protect ESG Investing

Today, President Biden issued the first veto of his presidency. This action had been heavily telegraphed in advance and was widely expected. Nonetheless, this veto is extraordinarily significant....more

SEC Continues Focus on ESG Issues in 2023 Examination Priorities

Last month, the SEC issued its list of examination priorities for 2023. Among the list of six priorities identified by the SEC in its press release was "Environmental, Social, and Governance (ESG)." Specifically, the SEC...more

SEC Commissioner Uyeda Suggests that ESG Disclosures Contribute to Decline in IPOs

In a recent lecture delivered at Columbia Law School/Business School at the "Going Public in the 2020s" conference, SEC Commissioner Uyeda bemoaned "the general decline in the number of public companies over the past...more

President Biden Threatens First Veto Over Congressional Nullification of DOL Regulation Enabling Consideration of ESG Factors

Last fall, the Biden Administration's Department of Labor ("DOL") issued a regulation ("Prudence and Loyalty in Selecting Plan Investments and Exercising Shareholder Rights") that, according to a White House press release,...more

Energy & Sustainability Litigation Updates — February 2023

Regulatory Developments - During the past several weeks, there have been a couple of notable developments in connection with the SEC’s proposed climate disclosures rule, “The Enhancement and Standardization of...more

California Legislators Propose Three Climate Bills Focused on ESG Disclosure and Investment

Three bills have recently been proposed by a trio of California state legislators concerning ESG financial disclosures and investing. The first, SB 253, would "require all large corporations that do business in California to...more

SEC Commissioner Questions ESG Investing

Last week, SEC Commissioner Uyeda delivered an address in which he "focus[ed] on issues related to asset managers' use of environmental, social, and governance (ESG) investment strategies." While his talk addressed many...more

Energy & Sustainability Litigation Updates - January 2023

Climate Change Litigation: Beginning in 2017, an array of state and local governments began pursuing claims against major fossil fuel producers — particularly the major oil companies (Chevron, Exxon, BP, Shell, and...more

Chair Powell States Federal Reserve is Not a "Climate Policymaker"

Today, Chair Powell of the Federal Reserve delivered a speech at the Symposium of Central Bank Independence in Stockholm, Sweden, in which he stated that the Federal Reserve is "not, and will not be, a 'climate policymaker,'"...more

Caremark Liability Following the SEC’s New ESG Reporting Requirements

Recent developments in the Court of Chancery concerning a corporate board’s duty to monitor and provide oversight over a corporation’s operations, so-called Caremark claims, are likely to intersect with the Securities and...more

Ratings Agencies Increase Focus on "Green Ratings"

S&P recently purchased Shades of Green, which has been described as "the largest external reviewer of sustainable bond and green financing frameworks." This acquisition emphasizes the recent strategic move by major ratings...more

Energy & Sustainability Litigation Updates — December 2022

SEC Enforcement: In its yearly summary of enforcement activity, the SEC chose to highlight ESG-related issues as one of only a handful of subject matter areas that the SEC is focused on, indicating the significant priority...more

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

SEC Highlights ESG Enforcement Activity in Annual Report

The SEC recently announced its yearly summary of enforcement activity. Among the items it chose to highlight were its efforts to enforce ESG-related issues. ESG was one of only a handful of subject matter areas that the SEC...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

Senate Republicans Issue Warning to Law Firms About Potential Antitrust Implications of ESG Activities

Last Thursday, five Republican senators--Cotton (AR), Grassley (IA), Rubio (FL), Lee (UT), and Blackburn (TN)--sent an identical letter to approximately fifty (50) major U.S. law firms, in which they stated that law firms...more

SEC States That Considering Diversity When Recommending Investment Advisers Is Consistent With An Advisor's Fiduciary Duty

Earlier this month, the SEC issued an FAQ concerning "an adviser's fiduciary duty when considering factors relating to diversity, equity, and inclusion (DEI) in the selection or recommendation of other investment advisers."...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

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

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