SEC Acting Chair Allison Herren Lee directed the SEC Division of Corporation Finance to review and update its 2010 guidance on climate change-related disclosure in public company filings. Ms. Lee stated that this review will include an assessment of public companies' compliance with disclosure obligations, which will be used to update the 2010 guidance and incorporate developments since its issuance.


While Chair Lee's remarks on the topic were quite short, it would not be surprising if they presaged very significant changes in SEC guidance on climate disclosures. One question to watch is whether the SEC will proceed in this area solely through guidance or whether it will attempt rulemaking.