Nick Grabar

Saturday, June 11, 2022 Print Tweet Nick Grabar is partner at Cleary Gottlieb Steen & Hamilton LLP. This post is based on a Cleary memorandum by Mr. Grabar, David Lopez, Francesca Odell, Lillian Tsu, and Helena Grannis. We think that moderating the proposal in key respects will—far from weakening it—make it more likely to achieve the Commission’s long-term purposes of eliciting useful and consistent disclosures.

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. The proposal is extremely ambitious, and it will place heavy new demands on public companies and the public disclosure system.

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.