Skip to main content
On March 21, 2022, the U.S. Securities and Exchange Commission voted to propose landmark amendments to its securities disclosure regulations titled “Enhancement and Standardization of Climate-Related Disclosures for Investors.” Through long experience with securities disclosure and ESG issues and through engagement with our valued clients, Bracewell understands how these requirements might not only fundamentally remake annual reporting as a discipline but also send shock waves through decades of your carefully planned business strategies and meticulously prepared systems of corporate governance. We fully recognize that this meal is too large to take on in a single sitting. The Bracewell corporate, environmental, ESG, government relations and litigation teams have prepared a series of alerts that are targeted to our core clientele.
Kevin Ewing led a tight, focused discussion of what matters in the new SEC climate disclosure rule. He discussed the key points of concern, their practical implications for mandatory and voluntary reporting, the status of rule-blocking litigation, and next steps...
The US Securities and Exchange Commission’s recently adopted rules governing climate-related disclosures, although significantly pared back from the rules proposed two years ago, represent a major change to the existing public-company disclosure regime. The rules require that public companies include...
The Congressional Review Act (CRA) is a legislative tool that Congress can use to undue regulations finalized by Executive Branch agencies. In particular, and in specific circumstances, the CRA is most powerful when utilized if there is a change in...
The US Securities and Exchange Commission has adopted a package of amendments, originally proposed in late 2021, to the disclosure requirements for corporate issuers’ share repurchases. The SEC stated that the new rules are designed to provide investors with more...
Things to Consider Rulemaking Coordinate closely with trades to ensure their comments reflect concrete information about impracticability and cost; these make a difference in the admin record upon judicial review Trade associations and industry groups are taking the lead on...
More than a year after creating its Climate and ESG Task Force in March 2021 , the Securities and Exchange Commission’s ESG-related enforcement goals are finally being realized. The SEC recently brought a fraud action against Vale S.A., a publicly...
The Securities and Exchange Commission’s Proposed Rules on Climate-Related Disclosure, released March 21, 2022, represent a significant change in public company disclosure requirements and, if adopted, will have far-reaching effects not only on all public companies but also on those...
As we have noted previously , the U.S. Securities and Exchange Commission’s recently proposed rules governing climate-related disclosures, if adopted as proposed, would represent a sea change to the existing public-company disclosure regime. We focus here on the corporate-governance aspects...
On March 21, 2022, the Securities and Exchange Commission (SEC) released its much-anticipated proposed rule on climate-related disclosure and accounting, “Enhancement and Standardization of Climate-Related Disclosures for Investors.” The scope and obligations of the 140-page proposal are gradually becoming clearer—and...
Among the many changes set forth in the U.S. Securities and Exchange Commission’s proposed rules governing climate-related disclosures are the attestation requirements 1 covering registrants’ greenhouse gas (GHG) emissions disclosures. This article provides a general overview of these attestation requirements...
The SEC’s proposed rule on climate-related risks includes amendments to both the financial reporting requirements (Reg S-X) and the narrative disclosure requirements (Reg S-K). The proposal interlinks the new requirements, drawing aspects of the required narrative disclosures into the financial...
The U.S. Securities and Exchange Commission’s recently proposed rules governing climate-related disclosures, if adopted as proposed, would represent a sea change to the existing public-company disclosure regime. The rules would require that public companies include the following, among other disclosures...