Environmental, Social and Governance: Climate-Related Comment Letter Themes

Today’s investors are placing greater emphasis on companies’ environmental, social and governance (ESG) disclosures. The Securities and Exchange Commission (SEC) is aware of this heightened interest in ESG matters and believes it is responsible for ensuring that investors have access to material information.

In March 2022, the SEC issued its proposed rule, The Enhancement and Standardization of Climate-Related Disclosures for Investors, to require companies to provide consistent, comparable, and reliable disclosure about climate-related matters. Even though this rule has not been finalized, the SEC staff has increased its focus on ensuring that companies comply with existing disclosure requirements under its 2010 Interpretive Release, Commission Guidance Regarding Disclosure Related to Climate Change, and 2021 Sample Letter to Companies Regarding Climate Change Disclosures.

CFGI and MyLogIQ have partnered to analyze frequently issued SEC staff comments associated with environmental and climate-related matters and have identified 11 recurring themes. This publication explores these themes and provides analysis and illustrative SEC staff comments that companies can leverage when preparing their 2022 year-end financial reporting.

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