SEC Disclosure Alert: Key Performance Metrics, Financial Reporting and Sustainability

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On January 30, 2020, the SEC issued guidance on the use of key performance metrics for public companies discussing their financial results and proposed amendments to certain financial reporting requirements. The published remarks of the SEC Chair Clayton and two other commissioners accompanying these actions show that there was also a dialogue about the role of the SEC in developing standards for reporting on environmental and climate-related issues, a topic not addressed in the guidance or proposals.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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