A few weeks ago, the SEC released its latest Reg Flex Agenda – and it has listed its climate disclosure rulemaking proposal as one that could potentially get completed by this October! Wow!

The extended comment period just ended for that proposal – although the SEC typically will review comment letters submitted after a deadline. And the Reg Flex Agenda tends to be “aspirational” as I have blogged about many times over the years.

In my blog handicapping when the SEC’s climate proposal may become final – and what it may look like when it does – I put the odds at the SEC adopting final rules during 2022 as 50/50 and I’m sticking with that ratio…

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Photo of Broc Romanek Broc Romanek

As a strategist for the firm’s Corporate & Securities practice, Broc Romanek has a deep understanding of the regulatory and environmental, social, and governance (ESG) marketplace. Prior to joining Perkins Coie, Broc served as editor at TheCorporateCounsel.net, CompensationStandards.com, and DealLawyers.com, where he oversaw…

As a strategist for the firm’s Corporate & Securities practice, Broc Romanek has a deep understanding of the regulatory and environmental, social, and governance (ESG) marketplace. Prior to joining Perkins Coie, Broc served as editor at TheCorporateCounsel.net, CompensationStandards.com, and DealLawyers.com, where he oversaw and managed coverage on issues related to ESG, corporate governance, executive pay, deals, and market trends and analysis.

In addition to his nearly two decades of working as a journalist and publisher, Broc served as assistant general counsel at a Fortune 50 company, worked in the Office of Chief Counsel of the U.S. Securities and Exchange Commission’s (SEC) Division of Corporation Finance, was a counselor to former SEC Commissioner Laura Unger, and worked in private practice. He also is the author, or co-author, of four legal treatises, and has authored several books focused on the legal industry.