TheCorporateCounsel.net

Ropes & Gray recently published a rundown of the comments submitted to the SEC in response to its ground-breaking climate change disclosure proposals. The memo notes:

By the time the comment period on the SEC’s proposed climate disclosure rules closed, the SEC had received approximately 14,000 comment letters. Over 1,000 of these letters were substantive, an extraordinarily high number. In this analysis, we provide statistics on the comment letters and note some of the many significant comment letters submitted.

The type of organization that submitted the most comment letters were, not surprisingly, trade associations, with the largest number in that category representing the financial services, agriculture and energy and extractive resources industries. There were 200 comment letters from corporations, representing a very significant turnout from individual issuers. Institutional investors were just behind corporations, submitting 133 letters. Other sources of comment letters include academia, consultants and service providers, standard-setting organizations, government, various think tanks and other organizations. The sheer volume and range of letters submitted in response to the proposal certainly gives the SEC staff and Commissioners a lot to consider when formulating final rules.

– Dave Lynn