On March 21, 2022, the U.S. Securities and Exchange Commission (SEC or Commission) issued its long-awaited proposed ruleset (Rule Proposal) that, if adopted as currently drafted, would mandate both domestic and foreign registrants to make a variety of climate-related impact and risk disclosures in registration statements and in annual filings under the Securities Exchange Act of 1934 (Exchange Act).
After months of individual Commissioners and the Chair promising to do so, on December 15, 2021, the US Securities and Exchange Commission (SEC) issued proposed amendments to Rule 10b5-1 of the Securities Exchange Act of 1934, as well as proposing a number of additional disclosure requirements.
In yet another step forward on the SEC’s path toward a comprehensive ESG disclosure framework, on September 22, 2021, the Staff of the Division of Corporation Finance issued a Sample Letter to Companies on Climate Change Disclosure, relying on the Commission’s 2010 Climate Change Guidance.