Climate change: 2022 SEC comment letter trends

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In each episode of our 2022 SEC comment letter trends series, our guests bring you the latest themes in comment letters from the SEC’s Division of Corporation Finance.

This week, Heather Horn was joined by Valerie Wieman, a partner in PwC’s National Office, to discuss a brand new comment letter trend in 2022: climate change disclosures. Given the SEC’s ESG-focused agenda, it is not a surprise that climate takes the #3 spot on our list of top comment letter trends.

In this episode you’ll hear discussion of:

• 0:56 - The history of the SEC’s focus on climate change and the issuance of the “Dear Issuer” letter of sample comments
• 3:57 - The existing 2010 SEC interpretive guidance on climate disclosures
• 8:58 - Specific examples of the types of comments frequently issued 
• 11:53 - Lessons learned from registrant responses to the first round of staff comment letters
• 15:18 - The importance of focusing on the 2010 interpretive guidance until the SEC’s proposed climate disclosure rule is final
• 17:56 - Val’s final advice for year-end reporting

Want to learn more? Check out our analysis of SEC comment letter trends and stay tuned for more episodes in the series. For more information on the SEC’s disclosure requirements pertaining to climate, read Don’t wait until the SEC staff asks you about climate change or listen to the audio version. To learn more about the SEC’s proposed climate disclosure requirements, listen to our podcast on the main provisions of the proposal.

Valerie Wieman is PwC’s National Office Editor-in-chief. She is involved in the creation, development, and publication of our brand-defining thought leadership, with a focus on ESG reporting. Prior to this role, she was part of PwC’s National Office SEC Services group, helping clients navigate SEC rules and regulations.

Heather Horn is PwC’s National Office thought leader, responsible for developing our communications strategy and conveying firm positions on accounting and financial reporting matters. She is the engaging host of PwC’s accounting and reporting weekly podcast and quarterly webcast series. With over 30 years of experience, Heather’s accounting and auditing expertise includes financial instruments and rate-regulated accounting.

Transcripts available upon request for individuals who may need a disability-related accommodation. Please send requests to [email protected].