The sample comments serve as an early warning to registrants that have not yet received any company-specific comments. The “Dear Issuer” letter further establishes that the SEC may review information disclosed outside of a public company’s SEC filings, including in separate sustainability reports, and asks public companies to consider whether they should also disclose such information in their SEC filings.
The sample comments in the letter are consistent with the guidance in the SEC’s 2010 interpretive release on climate-change disclosures, which covered four key topics: the impact of legislation and regulations, international accords, indirect consequences of regulation or business trends, and physical impacts of climate change. Throughout the conference, presenters discussed the SEC’s September 2021 ”Dear Issuer” letter that highlights the types of comments the Division may issue to public companies regarding their climate-related disclosures. Further, Munter noted that less than a third of companies that currently provide sustainability reporting have some form of assurance over the information, and the level and type of assurance are not consistent.
The information provided in the reports is typically not included in SEC filings, and lack of consistent reporting from issuer to issuer leads to lack of comparability. SEC Acting Chief Accountant Paul Munter observed that while a large number of issuers are currently providing some form of sustainability reporting, investors are looking for consistency in that reporting. During the opening session of the conference, former AICPA Chair Tracey Golden discussed investors’ and consumers’ changing expectations and the shift in focus from financial results to a business’s impact on the world around it.
0 kommentar(er)
