Given the heightened interest in the SEC’s proposed rule on climate, in a series of two blogs, I’ll be covering the nuts & bolts of sending in a comment letter to the SEC about a proposed rule.
This first blog covers the mechanics; the next blog will provide 8 tips about how to put your
This feature of our blog is where our in-house readers share tips, anecdotes and thoughts about things that come up in their daily practice. This particular batch of thoughts is about handling Rule 10b5-1 plans [feel free to ping me and share your thoughts – they will be posted anonymously or with attribution, whichever you
Following up on my blog entitled “7 Rules of Thumb for Subsidiary Governance,” on your annual calendar of “to-do” governance tasks, you should include a check-in as to whether you have any subsidiaries that have remained dormant for some time and are unlikely to be used again.
For some companies, this is easy.
Allison Handy and I have put together this 19-page guide entitled “The SEC’s Climate Disclosure Proposal: A Comprehensive Look.” Interestingly, the SEC has updated its proposing release several times since it was first posted – so the proposing release has shrunk by 20 pages, down to a slim 490 pages. We have updated the page
I’m excited to share our firm memo – “SEC Proposes New Cybersecurity Disclosure Rules on Incident Reporting, Risk Management, Strategy, and Governance” – authored by Valerie Dahiya and David Aaron. Check it out!
Digging further into the SEC’s proposing release for climate disclosure, the SEC’s proposal would elicit disclosure about a board’s oversight of climate-related matters. For some companies, this type of disclosure undoubtedly would impact how much time and resources they devote to climate issues going forward.
The Disclosure Requirements
As noted starting on page 93
Digging further into the SEC’s proposing release for climate disclosure, the SEC’s proposal would elicit disclosure about a company’s climate targets and goals – for those companies that have done that sort of thing.
We have blogged before about things to consider when companies publicly announce a climate pledge. Most companies making such pledges
This feature of our blog is where our in-house readers share tips, anecdotes and thoughts about things that come up in their daily practice. This particular batch of thoughts is about handling your relationship with Broadridge to get your proxy materials distributed [feel free to ping me and share your thoughts – they will be
Last week, one of California’s two board diversity statutes was ruled unconstitutional when the Los Angeles Superior Court issued a 24-page order granting summary judgment in Crest v. Padilla II. No word yet whether the State of California will appeal. As noted in this Idaho Statesman article, Judge Terry Green’s reasoning was:
Digging further into the SEC’s proposing release for climate disclosure, the SEC’s proposal would elicit disclosure about carbon offsets – for those companies that engage in that sort of thing. For some companies, carbon offsets and renewable energy credits or certificates (known as “RECs” and defined by the SEC consistent with how the EPA