On March 15, the SEC announced a 90 day consultation period on mandatory climate change disclosure. Acting Chair Lee cited to the December 2020 work of the ESG Sub-Committee of the Asset Management Advisory Committee which in turn endorsed the development of a taxonomy for disclosure by the Investment Company Institute. Chair Lee’s comments initially focused on Regulation S-K and S-X, while soliciting public comment, there is a focus on asset managers, potentially with a private equity/debt focus. Chair Lee posed this question: “What climate-related information is available with respect to private companies, and how should the Commission’s rules address private companies’ climate disclosures, such as through exempt offerings, or its oversight of certain investment advisers and funds.” Industry input over the next 90 days, might well determine the answer to this question.

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