{"id":2060,"date":"2021-09-23T11:44:44","date_gmt":"2021-09-23T15:44:44","guid":{"rendered":"https:\/\/seci.wpenginepowered.com\/?p=2060"},"modified":"2021-09-23T11:44:44","modified_gmt":"2021-09-23T15:44:44","slug":"corpfin-issues-sample-letter-to-companies-with-climate-change-comments","status":"publish","type":"post","link":"https:\/\/seciblog.pli.edu\/index.php\/corpfin-issues-sample-letter-to-companies-with-climate-change-comments\/","title":{"rendered":"CorpFin Issues Sample Letter to Companies With Climate Change Comments"},"content":{"rendered":"

On September 22, 2021, CorpFin staff posted this \u201cSample Letter to Companies<\/a>\u201d to provide example climate change disclosure comments.\u00a0 These Sample Letters, which are a successor to older \u201cDear CFO\u201d letters, provide illustrative comments about emerging and \u201chot-button\u201d issues companies should consider in their disclosure processes. (For example, one of the previous letters dealt with securities offerings during times of extreme price volatility<\/a>.)<\/p>\n

This Sample Letter<\/a> is a next step in CorpFin\u2019s focus on climate change, which was directed by then Acting Chair Allison Herren Lee in this February 24, 2021 Public Statement<\/a>.<\/p>\n

The Sample letter references the SEC\u2019s current climate change disclosure guidance in FR-82 (Release 33-9106, 34-61469) Commission Guidance Regarding Disclosure Related to Climate Change<\/a>.<\/p>\n

Many of the example comments have their roots in FR-82.\u00a0 For example, FR-82 includes this paragraph dealing with separate ESG reports that many companies issue:<\/p>\n

\u201cAlthough much of this reporting is provided voluntarily, registrants should be aware that some of the information they may be reporting pursuant to these mechanisms also may be required to be disclosed in filings made with the Commission pursuant to existing disclosure requirements.\u201d<\/p>\n

The Sample Letter<\/a> includes this related example comment:<\/p>\n

General<\/u><\/p>\n

    \n
  1. We note that you provided more expansive disclosure in your corporate social responsibility report (CSR report) than you provided in your SEC filings.\u00a0 Please advise us what consideration you gave to providing the same type of climate-related disclosure in your SEC filings as you provided in your CSR report.<\/li>\n<\/ol>\n

    The Sample Letter<\/a> focuses on risk factor and MD&A disclosure and, consistent with topics addressed in FR-82, provides example comments focused on indirect and physical effects of climate change.<\/p>\n

    As we move towards our next quarter and year-end reporting cycles, and as disclosure committees consider current disclosure issues, this letter is a reminder to review FR-82 and any other climate change related reports our companies and clients prepare and to carefully consider how to address these matters in our reporting.<\/p>\n

    You can learn more and review the SEC\u2019s Request for Comment on Climate Disclosure<\/a> on this ESG section of SEC.gov<\/a>.<\/p>\n

    As always, your thoughts and comments are welcome!<\/p>\n","protected":false},"excerpt":{"rendered":"

    On September 22, 2021, CorpFin staff posted this \u201cSample Letter to Companies\u201d to provide example climate change disclosure comments.\u00a0 These Sample Letters, which are a successor to older \u201cDear CFO\u201d letters, provide illustrative comments about emerging and \u201chot-button\u201d issues companies should consider in their disclosure processes. (For example, one of the previous letters dealt with … Continue reading CorpFin Issues Sample Letter to Companies With Climate Change Comments<\/span> →<\/span><\/a><\/p>\n","protected":false},"author":9,"featured_media":0,"comment_status":"open","ping_status":"open","sticky":false,"template":"","format":"standard","meta":{"jetpack_post_was_ever_published":false,"_jetpack_newsletter_access":"","_jetpack_dont_email_post_to_subs":false,"_jetpack_newsletter_tier_id":0,"_jetpack_memberships_contains_paywalled_content":false,"_jetpack_memberships_contains_paid_content":false,"footnotes":"","jetpack_publicize_message":"","jetpack_publicize_feature_enabled":true,"jetpack_social_post_already_shared":true,"jetpack_social_options":{"image_generator_settings":{"template":"highway","default_image_id":0,"font":"","enabled":false},"version":2},"_wpas_customize_per_network":false},"categories":[143,242],"tags":[],"coauthors":[154],"class_list":["post-2060","post","type-post","status-publish","format-standard","hentry","category-hot-topic","category-reporting"],"jetpack_publicize_connections":[],"jetpack_featured_media_url":"","jetpack_sharing_enabled":true,"post_mailing_queue_ids":[],"_links":{"self":[{"href":"https:\/\/seciblog.pli.edu\/index.php\/wp-json\/wp\/v2\/posts\/2060","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/seciblog.pli.edu\/index.php\/wp-json\/wp\/v2\/posts"}],"about":[{"href":"https:\/\/seciblog.pli.edu\/index.php\/wp-json\/wp\/v2\/types\/post"}],"author":[{"embeddable":true,"href":"https:\/\/seciblog.pli.edu\/index.php\/wp-json\/wp\/v2\/users\/9"}],"replies":[{"embeddable":true,"href":"https:\/\/seciblog.pli.edu\/index.php\/wp-json\/wp\/v2\/comments?post=2060"}],"version-history":[{"count":0,"href":"https:\/\/seciblog.pli.edu\/index.php\/wp-json\/wp\/v2\/posts\/2060\/revisions"}],"wp:attachment":[{"href":"https:\/\/seciblog.pli.edu\/index.php\/wp-json\/wp\/v2\/media?parent=2060"}],"wp:term":[{"taxonomy":"category","embeddable":true,"href":"https:\/\/seciblog.pli.edu\/index.php\/wp-json\/wp\/v2\/categories?post=2060"},{"taxonomy":"post_tag","embeddable":true,"href":"https:\/\/seciblog.pli.edu\/index.php\/wp-json\/wp\/v2\/tags?post=2060"},{"taxonomy":"author","embeddable":true,"href":"https:\/\/seciblog.pli.edu\/index.php\/wp-json\/wp\/v2\/coauthors?post=2060"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}