Summary Outline of SEC’s Proposed Rule on Climate-Related Disclosure and Accounting

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The SEC’s proposed rule on climate-related risks includes amendments to both the financial reporting requirements (Reg S-X) and the narrative disclosure requirements (Reg S-K).  The proposal interlinks the new requirements, drawing aspects of the required narrative disclosures into the financial statement.  The proposed changes are complex and detailed.  The preamble to the proposal offers interpretive guidance, but the proposed regulatory language itself merits close study apart from the preamble.  What follows is a précis of the key proposed requirements, with hyperlinks to the actual language as found in the pre-publication copy of the proposal.

By: Kevin A. EwingTroy L. HarderCharles H. Still Jr., and Nathan Guerra

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