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California Compels Disclosure of Greenhouse Gas Emissions by Major Companies Operating in California

Earlier this month, Governor Newsom announced his support of a sweeping climate bill enacted by the California legislature that would compel major companies operating in California to disclose their greenhouse gas emissions. ...more

SEC Approves "Names" Rule to Combat Greenwashing

On September 20, 2023, the SEC approved amendments to the "Names Rule," which were initially proposed in May 2022. Although the stated "purpose of the Names Rule," according to the accompanying Fact Sheet distributed by the...more

SEC Re-Affirms Commitment to Climate Risk Disclosure Rule

On September 12, 2023, SEC Chairman Gensler testified before the Senate concerning a number of significant issues for the SEC. Among them was the SEC's still-pending rule on climate risk disclosures, which was first proposed...more

Energy & Sustainability Litigation Updates - August 2023

Public media reports have stated that the SEC’s Enforcement Division has been “sen[ding] document requests, including subpoenas” to asset managers in connection with ESG marketing. Apparently, these actions by the SEC’s...more

Securities Lawsuit Against Retailer Due to Losses Allegedly Caused By Conservative Boycott Due to Company's Embrace of Pro-LGBTQ...

This week, an investor brought a lawsuit against Target Corporation in connection with allegedly "false and misleading statements concerning Target's Environment, Social and Governance (ESG) and Diversity, Equity, and...more

SEC Possibly Conducting Industry Sweep of ESG Investment Funds

It has been publicly reported that the SEC's Enforcement Division has been "sen[ding] document requests, including subpoenas" to asset managers in connection with ESG marketing.  This development is entirely unsurprising, as...more

Montana Judge Rules That Youth Plaintiffs' Right to a Healthy Environment Includes Consideration of the Impact of GHG Emissions...

Today, a state court judge in Montana issued a long-awaited ruling in which the court found that the "Plaintiffs have a fundamental constitutional right to a clean and healthful environment, which includes climate as part of...more

CFTC Holds Second Voluntary Carbon Markets Convening

Yesterday, on July 19, 2023, the CFTC held its second voluntary carbon markets convening, approximately a year following the initial voluntary carbon markets convening on June 2, 2022. The stated purpose of the meeting is...more

House Financial Services Committee Criticizes ESG Regulations and Activism in Corporate America

Last week, the House Financial Services Committee held a hearing entitled "Protecting Investor Interests: Examining Environmental and Social Policy in Financial Regulation." As indicated by the title of the hearing, the...more

House Republicans Issue Letters to Major Asset Managers Concerning Potential Antitrust Violations Allegedly Caused by ESG Policies

This week, Congressmen Jim Jordan (R-OH), Thomas Massie (R-KY), and Dan Bishop (R-NC), sent a letter on behalf of the House Committee on the Judiciary to three major asset managers and two non-profit organizations (the...more

New ESG Requirements for Banks that Hold Public Funds May Raise Challenging Compliance Issues

Much ink has been spilled about ESG laws and regulations targeted at the investment of public funds, and rightfully so.  Yet, there has been little discussion of novel requirements imposed on banks that simply hold state or...more

CFTC Asserts Enforcement Authority Over Carbon Markets

Last week, the CFTC solicited whistleblowers in connection with "potential [] fraud and manipulation" in "voluntary carbon markets," particularly in circumstances "in which high-quality carbon credits, also known as carbon...more

SEC Commissioner Proposes Limits to Shareholder Proposals on Environmental and Social Issues

SEC Commissioner Uyeda, one of two Republican commissioners on the Securities & Exchange Commission, delivered remarks yesterday at the Society for Corporate Governance's National Conference, in which he broached the idea...more

SEC Climate Change Disclosure Rule Expected in October 2023

This week, the Securities & Exchange Commission indicated--through an update to a GSA website --that the proposed climate change disclosure rule would likely be finalized and released in October 2023. This date is congruent...more

How Does Climate Change Create Financial Risk? Ask Insurance Companies.

Much of the current debate about ESG initiatives and how companies consider the impact of climate change on their operations appears to operate in a vacuum, untethered to the real world, where pundits and politicians opine on...more

SEC Commissioner Peirce Continues to Criticize Proposed ESG Rules

Recently, SEC Commissioner Peirce--one of the Republican appointees to the Securities & Exchange Commission--delivered a speech to Eurofi (a European think tank focused on financial regulation) in which she extensively...more

Supreme Court Rejects Efforts By Fossil Fuel Companies to Litigate Climate Change Issues in Federal Court

Today, the Supreme Court denied the writ of certiorari filed by the major oil companies in a pair of significant climate change cases. Specifically, the fossil fuel companies had sought review of a decision by the Third...more

Proposed SEC Climate Disclosure Rule Potentially Delayed Until Fall 2023

About two weeks ago, former SEC Commissioner Robert Jackson, currently a professor at NYU Law, stated during an April 27 webinar hosted by a carbon accounting firm that "it looks like the [climate disclosure] rule is going to...more

Florida's Latest Anti-ESG Efforts

Today, Governor DeSantis (R-FL) signed into law an anti-ESG bill that, among other things, bars managers of the state's pension fund from considering ESG factors when making investments.  Instead, pecuniary factors are the...more

EPA to Announce Proposed Regulation To Control GHG Emissions From Power Plants

It has been publicly reported that the Biden Administration's EPA will shortly "announce limits on greenhouse gas emissions from power plants that could compel them to capture the pollution from their smokestacks."  In...more

SEC Commissioner Voices Strong Support for Proposed SEC Climate Disclosure Rule and Related Proposed ESG Disclosure Rules

SEC Commissioner Lizarraga, one of the recent Democratic appointees to the Securities & Exchange Commission, delivered a speech on April 18 at the annual public policy symposium of the North American Securities Administrators...more

SEC Chairman Gensler Reinforces Commitment of SEC to Climate Disclosures

Last week, SEC Chairman Gensler testified before the House Committee on Financial Services.  As part of his talk, which addressed a number of topics--including, inter alia, artificial intelligence and crypto--Chairman Gensler...more

Energy & Sustainability Litigation Updates — March 2023

State and Local ESG Regulation. Despite recent public statements by notable Republican federal officials, including an SEC Commissioner, that have expressed considerable skepticism towards the SEC’s proposed ESG...more

President Biden Issues First Veto to Protect ESG Investing

Today, President Biden issued the first veto of his presidency. This action had been heavily telegraphed in advance and was widely expected. Nonetheless, this veto is extraordinarily significant....more

SEC Continues Focus on ESG Issues in 2023 Examination Priorities

Last month, the SEC issued its list of examination priorities for 2023. Among the list of six priorities identified by the SEC in its press release was "Environmental, Social, and Governance (ESG)." Specifically, the SEC...more

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