“SEC Issues Interpretive Guidance on Climate Change Disclosure”
On February 2, 2010, the Securities and Exchange Commission, (the “SEC”) issued Release Nos. 33-9106; 34-61469; FR-82: “Commission Guidance Regarding Disclosure Related to Climate Change” (the “Release”). The Release notes that regulatory, legislative and other developments related to climate change “could have a significant effect on operating and financial decisions” of reporting companies, but does not introduce any new disclosure requirements. Rather, the Release is intended to provide public companies with guidance regarding the SEC’s existing disclosure requirements “as they apply to climate change matters.”
This Stroock Special Bulletin provides an overview of some of the key issues discussed in the Release.