Shareholder Activists and Institutional Investors
Again Petition SEC to Provide Guidance on
Climate Change Disclosure

December 3, 2009

A coalition of shareholder activists and institutional investors is again petitioning the SEC to issue interpretive guidance regarding the disclosure of material information about climate change-related risks and opportunities by public companies.  This latest move is the continuation of a campaign that goes back to at least September 2007, when these activists and investors initially formally petitioned the SEC to issue climate change guidance.  The supplemental petition, filed on November 23, 2009, describes regulatory and scientific developments regarding climate change over the past two years, and argues that guidance from the SEC is necessary to improve the quality and quantity of climate change disclosure, which is currently deficient, according to the coalition.  Signatories to the supplemental petition include the California Public Employees’ Retirement System, the California State Teachers’ Retirement System, the New York State Attorney General, the New York State Comptroller and a number of state treasurers and financial officers. 


See the supplemental petition to the SEC filed on November 23, 2009.

See the Davis Polk memorandum entitled Environmental Disclosure in SEC Filings, which discusses previous requests for SEC climate change guidance on pages 44 through 46.


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