1. What the Volume and Diversity of Comment Letters to the SEC Say About its Climate Proposal

    What the Volume and Diversity of Comment Letters to the SEC Say About its Climate Proposal

    The Securities and Exchange Commission presents its new climate proposal as a modest evolution in its longstanding rules requiring environmental disclosure. While supporters echo that pitch, most recognize the proposal as a large leap beyond the SEC’s traditional focus on material financial matters. Who has the better of it may be inferred from the breadth of comments the SEC’s proposal received during the three-month comment period that ended June 17...

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