As you are likely aware, the SEC published in March 2022 an ambitious proposal to require public companies to provide climate-related disclosures. If the proposal is adopted – which seems likely, at least in some form – it will place heavy new demands on public companies and require them to provide climate-related information in their registration statements and annual reports filed with the SEC.
Continue Reading Cleary Submits Comments on SEC Climate Proposal
SEC Guidance
Cleary Provides Comments on Underwriter Provisions of SEC SPAC Proposal
By Cleary Gottlieb on
Posted in Boards of Directors, SEC Guidance
In March 2022, the SEC proposed a package of rules and rule amendments governing special purpose acquisition companies (SPACs), SPAC initial public offerings (IPOs) and SPAC mergers with a target company (de-SPACs). Among those provisions was proposed new Rule 140a, which would provide that any underwriter in a SPAC IPO that “takes steps to facilitate…
Cleary Provides Detailed Comments on SEC Climate Proposal
By Cleary Gottlieb on
Posted in Boards of Directors, SEC Guidance
The SEC published in March 2022 an ambitious proposal to require public companies to provide climate-related disclosures. If the proposal is adopted – which seems likely, at least in some form – it will place heavy new demands on public companies and require them to provide climate-related information in their registration statements and annual reports…
Proposed SEC Climate-related Disclosure Rules
By Cleary Gottlieb on
On April 21, 2022, Cleary Gottlieb partners Nicolas Grabar and Francesca Odell, and associate Shuangjun Wang participated in the Governance Watch Webcast, “Briefing on Proposed SEC Climate-Related Disclosure Rules,” organized by Cleary and The Conference Board ESG Center.
The discussion focused on the long-awaited SEC proposal on climate-related disclosure rules, how companies should get…
The SEC Climate Disclosure Proposal – Top Ten Issues for Comment
By Cleary Gottlieb on
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…
The SEC’s Climate Proposal – Top Points for Comment
By Nick Grabar, Lillian Tsu & Nikta Daijavad on
The SEC published in March 2022 a dauntingly complex proposal to require public companies to provide climate-related disclosures.[1] The period for public comment on the proposal is very short, and it seems clear that a majority of the Commission is determined to proceed quickly. …
Continue Reading The SEC’s Climate Proposal – Top Points for Comment
SEC’s Proposed Climate-Related Disclosure Rules: New Requirements Added to Regulation S-K
By Cleary Gottlieb on
On March 21, 2022, the U.S. Securities and Exchange Commission issued for public comment a rule proposal that, if adopted, would require reporting companies to provide certain climate-related information in their registration statements and annual reports filed with the SEC. Specifically, the proposed rules would require:
- A new section in annual reports and registration statements
…
SEC’s Proposed Climate-Related Disclosure Rules: GHG Emissions Disclosure Requirements
By Cleary Gottlieb on
On March 21, 2022, the U.S. Securities and Exchange Commission issued for public comment a rule proposal that, if adopted, would require reporting companies to provide certain climate-related information in their registration statements and annual reports filed with the SEC. Specifically, the proposed rules would require:
- A new section in annual reports and registration statements
…
SEC’s Proposed Climate-Related Disclosure Rules: The Climate Note to Audited Financial Statements
By Cleary Gottlieb on
On March 21, 2022, the U.S. Securities and Exchange Commission issued for public comment a rule proposal that, if adopted, would require reporting companies to provide certain climate-related information in their registration statements and annual reports filed with the SEC. Specifically, the proposed rules would require:
- A new section in annual reports and registration statements
…
SEC Proposes New Disclosure Rules for Cybersecurity Incidents and Governance
By Helena K. Grannis & Anthony M. Shults on
Last month, the U.S. Securities and Exchange Commission issued a proposal to enhance and standardize disclosure requirements related to cybersecurity incident reporting and cybersecurity risk management, strategy, and governance. Among other changes, the SEC’s proposal would require disclosure about material cybersecurity incidents within four business days and require annual disclosure regarding a registrant’s policies and…