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Cool Response: The SEC & Corporate Climate Change Reporting

This report examines the state of corporate reporting and associated SEC comment letters on climate change. It also provides recommendations for the SEC and companies on improving the quality of reporting.

Climate change and its regulation pose significant risks and opportunities to investors and corporations. The nearly $30 billion in insured losses from Hurricane Sandy alone dramatically underscore this reality. New climate-related federal and state regulations in recent years also present risks and opportunities to companies in the electric power, coal, oil & gas, transportation and insurance sectors. Investors seek greater transparency and disclosure on the business risks of climate change as a means to protect and increase shareholder value.

The key regulator that leads federal efforts to provide investors with information about corporate risks and opportunities is the U.S. Securities and Exchange Commission (SEC). At the heart of the SEC’s mission is the protection of investors through meaningful corporate reporting.

The SEC recognized the financial impacts of climate change when it issued Interpretive Guidance on climate disclosure in February 2010, responding to over 100 institutional investors representing $7 trillion who supported the Guidance. The Guidance outlines expectations from companies in reporting on “material” regulatory, physical, and indirect risks and opportunities related to climate change.

This report examines the state of such corporate reporting and associated SEC comment letters on climate change. It also provides recommendations for the SEC and companies on improving the quality of reporting.

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