As we mentioned last week, the signals coming from the SEC on ESG matters are increasing in volume and significance. On March 15, acting SEC Chair Allison Herren Lee added two more data points.

The first concerned the Division of Corporate Finance’s disclosure program. Due to the fact that the SEC hasn’t updated its climate change guidance since 2010, Lee solicited input from the public on updating the SEC’s disclosure rules as they pertain to climate change (and governance) through the 15 questions posed here. The questions posed go directly to the quality and quantity of disclosures registrants are providing in their SEC filings.

Perhaps more importantly, Lee left no doubt in her view that what is needed is “development of a dedicated standard setter for ESG (similar to FASB) under SEC oversight to devise an ESG reporting framework that would complement our financial reporting framework.” That indicates the degree of seriousness with which the current Commission is taking ESG matters.

No doubt, there is more to come.

If you have any questions please contact David Lavan or your Dinsmore attorney.