Full Title: Cool Response: The SEC & Corporate Climate Change Reporting
Author(s): Jim Coburn and Jackie Cook
Publication Date: February 1, 2014
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The SEC recognized the financial impacts of climate change when it issued Interpretive Guidance on climate disclosure in February 2010, responding to over 100 institutional investors representing $7 trillion who supported the Guidance. The Guidance outlines expectations from companies in reporting on “material” regulatory, physical, and indirect risks and opportunities related to climate change.
This report examines the state of such corporate reporting and associated SEC comment letters on climate change. It also provides recommendations for the SEC and companies on improving the quality of reporting.