Monday, May 10, 2021 While the U.S. Securities and Exchange (SEC) has not been very active in holding companies accountable for failing to report climate-related information, litigation under state provisions—and the growing urgency of climate-related risks—has shown the need for more active enforcement. In recent years, states have pursued companies for allegedly making misleading financial disclosures in violation of state statutes. In 2015, for example, the New York Attorney General entered into a settlement with Peabody Energy Corporation involving misleading disclosures under New York-specific statutes. After subpoenaing internal records that showed the company had made internal market projections showing severe negative impacts from certain potential laws and regulations and had failed to disclose those projections to the public, the company