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Overview
The SEC CorpFin staff continues to issue climate-related comments based on the risks and issues identified in FR 82 – Commission Guidance Regarding Disclosure Related to Climate Change (Release 33-9106). Comments have addressed several challenging areas, including the impact of climate-related risks and events on governance and risk management processes, materiality, and climate-related financial statement impacts. Additionally, the staff has asked why information in separate ESG reports is not included in SEC filings. This Briefing will begin with a brief review of the SEC’s existing climate-related disclosure guidance. This guidance will be applied to detailed real-world examples of company disclosures and the SEC comments and company responses related to those disclosures. Based on these examples, discussion will address how to avoid SEC comments and potentially worse outcomes related to climate-related disclosures.
Please join our discussion leaders Bob Laux and George M. Wilson of PLI’s SEC Institute for this review of SEC climate-related comments.
Topics include:
- Review of the SEC’s guidance for climate-related disclosures – 10 Minutes
- FR 82 – Release 33-9106
- Existing Regulation S-K climate-related disclosures
- Existing Regulation S-X climate-related disclosures
- Brief update on the status of the SEC’s March 2024 climate-related disclosure final rules
- Discussion of frequent comment issues for climate-related information – 5 minutes
- Detailed real-world examples of company disclosures and subsequent SEC comments – 10 minutes
- Explanation of the basis for each SEC comment – 10 minutes
- Detailed examples of company responses and follow-on SEC comments – 15 minutes
- Discussion of how to avoid climate-related comments – 10 minutes
Program Level: Update
Intended Audience: Accountants and attorneys who deal with SEC reporting and disclosure and related accounting issues, including CFOs, controllers and their staff, internal auditors, partners of public accounting firms and their staff, in-house counsel, and outside attorneys
Prerequisites: None
Advanced Preparation: None