We also make several recommendations related to the disclosures being proposed by the SEC in the Release. Given our view on the most important disclosures and the potentially challenging proposed implementation dates, we propose an alternative path forward summarized in this document.

Our positions cover the following topics:

OVERARCHING CONSIDERATIONS

1. Inclusion of Climate Disclosures in Financial Statements: A Step Beyond the Rest of the Globe.
2. Information Must Be Decision-Useful and Predictive: A Link Is Needed Between Disclosures Inside and Outside Financial Statements.
3. Reference to, or Lack of Reference to, Relevant Frameworks.
4. Climate-Related Definitions.
5. Materiality.
6. Relevance vs. Reliability.
7. Safe Harbors.
8. The Private Company Implications from Emission Disclosures.
9. Discussion in Proposal vs. Actual Rule.
10. Climate Disclosures: Balance Financial Reporting Improvements.

     

    DISCLOSURES OUTSIDE FINANCIAL STATEMENTS (REGULATION S-K) – OTHER THAN GHG EMISSIONS

    1. Requirements Relative to Existing S-K Requirements.
    2. Overview of Climate-Related Reporting Framework.
    3. Disclosure of Climate-Related Risks
    4. Disclosures Regarding Climate-Related Impacts on Strategy, Business Model, and Outlook.
    5. Governance Disclosure
    6. Risk Management Disclosure

    DISCLOSURES OUTSIDE FINANCIAL STATEMENTS (REGULATION S-K) – GHG EMISSIONS

    1. GHG Emission Disclosure Requirements.
    2. GHG Emissions Metrics Disclosure.
    3. GHG Emissions Methodology and Related Instructions.
    4. Scope 3 Emissions Disclosure Safe Harbor and Other Accommodations.
    5. Attestation of GHG Emission Disclosures.
       1. Attestation of Scope 1 and Scope 2 Emissions Disclosure.
       2. GHG Emissions Attestation Provider Requirements.
       3. GHG Emissions Attestation Engagement and Report Requirements and Additional Disclosure by the Registrant.
       4. Disclosure of Voluntary Attestation May Discourage Registrants from Seeking Such Attestation.

    DISCLOSURES INSIDE FINANCIAL STATEMENTS (REGULATION S-X)
    
    

11. Positions and Comments.
12. Financial Impact Metrics.
13. Expenditure Metrics.
14. Assumptions and Estimates.
15. Inclusion of Climate-Related Metrics in Financial Statements.

ALTERNATIVE APPROACH

1. Forward-Looking, Decision-Useful and Predictive.
2. Preferred Alternative Disclosures: Cash Metrics.

POSITIONS AND COMMENTS

1. Applicability and Implementations Dates.
2. Structured Date Requirements.
3. Treatment for Purposes of Securities Act and Exchange Act.
4.  Compliance Date.