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SEC Comments on Environmental Matters

While environmental, social and governance (ESG) may soon see a seismic shift in disclosure requirements, there has been no shortage of regulatory scrutiny based on existing requirements.

The U.S. Securities and Exchange Commission’s (SEC or Commission) Division of Corporation Finance (Corp-Fin) has been busy on the environmental, social and governance (ESG) ESG disclosure front through comments to SEC registrants (i.e., public companies). Understanding the SEC comment letter process and current trends is important in keeping within the good graces of this important regulator.

This article focuses on the ’E’ of ESG by drawing attention to recent environmental and climate-related comments through a report conducted by MyLogIQ entitled An Analysis of Climate Related Comment Letter Themes (Report). This Report is based on research from MyLogIQ’s comment letter database and analyses 620 environmental and climate-related comments issued by Corp-Fin to 76 public companies between July 2021 and January 2023.

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