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The Securities and Exchange Commission (SEC) announced in recent
weeks multiple efforts to highlight climate change in corporate
disclosures and to increase scrutiny and, potentially, enforcement
focus on company disclosure efforts on climate and other
environmental, social, and governance (ESG) matters. While
the topic of ESG disclosures is not new, the increased attention to
the topic, and climate change in particular, is noteworthy and
expected to remain an area of focus at the SEC and under the Biden
Administration more broadly.
Existing Frameworks
The question of whether and what companies should disclose to
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