Environmental Disclosure in SEC Filings – 2011 Update
Client Memorandum

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This memorandum, which updates our January 2009 and February 2010 memoranda on this topic, summarizes the key developments in the past year relating to environmental disclosure and provides practical guidance on how to comply with the complex SEC rules relevant to environmental matters. In particular, the memorandum discusses (i) updates regarding SEC climate change disclosure; (ii) potential revisions to the SEC's risk factor disclosure standards; (iii) an update on the New York Attorney General's climate risk disclosure subpoenas; and (iv) FASB's ongoing efforts to expand its requirements governing loss contingency disclosures.

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