The SEC’s proposal to require climate-related disclosures is almost surely headed for adoption.  We think moderating it in key respects will make it more effective, and we have developed a Top Ten List of points for comment.  The list focuses on areas where the SEC may have gone too far, getting ahead of what investors want and what companies can do, and risks undermining its own goal of promoting consistent and useful disclosures.

Please click here to read the full alert memorandum.