SEC Should Build off its Traditional Disclosure Principles when it Comes to Climate

Washington, D.C. – BPI today recommended to the SEC that any new climate disclosure requirements build off its existing regime, which focuses on providing material information to investors.  The comment letter also notes the uncertainty inherent in certain climate disclosures given reliance on third parties for information and differences in measuring emissions. The letter also recognizes the crucial role that the SEC will play in international efforts to develop a global climate disclosure standard.

“Banks are already voluntarily disclosing climate-related information, but climate disclosure for banks derives overwhelmingly from the underlying emissions data of their clients. Currently, this data is far from standardized or consistent,” said BPI Senior Vice President and Associate General Counsel Lauren Anderson. “That said, this area is one where the underlying science and risk management are evolving rapidly, so it is important that any SEC regime allow for experimentation and even mistakes without triggering enforcement actions that would push public companies to say less rather than more.”

BPI proposes that the SEC consider the following points as it considers whether to require new climate disclosures from public companies.

  • Appropriate limits on liability for climate disclosures, particularly with regard to information obtained from third parties and outside the control of registrants;
  • Separation of any climate disclosure requirements from securities filings, such as 10-K and 10-Q reports; and
  • No requirement for audit or assurance processes at this time for new climate disclosures given data and analytical limitations.

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About Bank Policy Institute.

The Bank Policy Institute (BPI) is a nonpartisan public policy, research and advocacy group, representing the nation’s leading banks and their customers. Our members include universal banks, regional banks and the major foreign banks doing business in the United States. Collectively, they employ almost 2 million Americans, make nearly half of the nation’s small business loans, and are an engine for financial innovation and economic growth


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Sean Oblack
Bank Policy Institute
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