Do you expect the SEC’s new climate disclosure rules, if finalized, will change the scope of its ESG-related enforcement actions?
Enforcement actions covering topics that are now known as ESG-related are not new. Historically, these actions typically alleged violations of disclosure controls and procedures or material misstatements, as noted above. However, the SEC’s proposed climate rules would require detailed information about a company’s climate-related risks, greenhouse gas emissions, and climate-related financial metrics and targets, vastly increasing the amount of information disclosed in securities filings. As a result, the SEC would have more areas to police and companies would have more areas to govern with internal controls and procedures.
‘Enforcement 40’ for 2020
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