In Harvard Law School Forum on Corporate Governance, Michael Littenberg and Marc Rotter Examine Climate Change Disclosures in SEC Filings
The Harvard Law School Forum on Corporate Governance published an article co-authored by partner and ESG, CSR and Business and Human Rights practice chair Michael Littenberg and capital markets counsel Marc Rotter (both of New York) on climate change disclosures in SEC filings.
The staff of the U.S. Securities and Exchange Commission’s Division of Corporation Finance recently published a sample comment letter relating to climate change disclosures. The authors note that while the sample letter does not break new ground substantively, it underscores the SEC’s increasing focus on climate disclosures in public company filings and its views on the relevance to investors of climate-related risks. In the article, the authors discuss the sample comment letter and take-aways for public companies.