More on the SEC Staff issuing “climate” comments

SEC Staff Climate YouTube Thumbnail

Recently, I blogged that it didn’t appear that the SEC Staff was issuing too many climate comments. Perhaps that’s not quite true as the Staff continues to release additional comment letters. We’ll soon see. Anyway, as noted by this blog by Cooley’s Cydney Posner, Audit Analytics has posted its own analysis of the Staff’s recent climate comments. Here’s a notable excerpt from Cydney’s blog:

Interestingly, Audit Analytics indicates that all of the companies received a second round of comments addressing company responses to the initial round. In the second round, there were 4.8 comments per letter, with a range of one to six comments. The leitmotif of comments in round two was “materiality”— both quantitative and qualitative. Often, in response to one or more comments, companies advised that they did not disclose certain matters because they were not viewed to be material.

In many of those cases, the SEC indicated that they viewed the companies’ responses to be conclusory and pressed the companies to drill down and, as Audit Analytics phrased it, “show their work” in their responses by providing quantitative details or more detailed explanations to justify their conclusions.