On March 15, 2020, Allison Lee, Acting Chair of the Securities and Exchange Commission (SEC), delivered comments at the Center for American Progress via webcast, announcing the opening of a comment period regarding climate change disclosures. The submissions are to be used in developing future guidance and proposals on ESG (Environmental, Social and Governance) issues. In delivering her prepared remarks, Lee indicated the SEC is undertaking concrete steps to develop and implement a mandatory ESG disclosure framework. The Biden Administration has made climate change and other ESG matters a key priority.

Norton Rose Fulbright has issued a legal update, “SEC makes clear an ESG disclosure framework is coming and opens comment period on potential climate change disclosures.” Authors Kevin Harnisch, Head of the firm’s US Regulation, Investigations, Securities and Compliance practice and Partner in the Washington, DC office, Houston office Partner Trevor Pinkerton, New York office Partner Seth Kruglak, Houston office Senior Counsel Todd Batson, and Houston Associate James Larkin Smith, discuss both Acting Chair Lee’s comments and the proposal, and the proposal’s questions on which the SEC is particularly interested in receiving feedback.