The SEC’s request for comment on climate disclosure, explained

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Given the increase in demand for climate change information and the ongoing debate regarding whether the current disclosures provide sufficient decision-useful information for investors, the SEC’s then-Acting Chair Allison Lee issued a public statement in which she requested input from market participants on climate change disclosure. 

In this week’s episode, Heather Horn and PwC’s National Office team leading PwC’s comment letter response, comprising Kyle Moffatt, Andreas Ohl, Jay Sivakumaran, and Valerie Wieman, discuss considerations for responding to the SEC’s request.

Topics include:

• 0:50 - Overview and background. Val, Kyle, Andreas, and Jay explain what the common themes are in the SEC’s questions and what prompted the request for comment. 
• 8:38 - Standard setting. Andreas and Kyle explain the current landscape of standard setting in the US and globally, what it means for ESG reporting, and what the future of standard setting may look like. 
• 14:22 - Industry considerations. Val and Andreas give their views on industry-specific standards versus a universal approach. 
• 17:59 - Measurements. Andreas explains the questions on measurements and what companies should consider as it relates to metrics.
• 24:54 - Geography of disclosures. Val and Kyle share their point of view on the geography of disclosures and what they feel matters most.
• 28:42 - Assurance and governance. Jay shares considerations on assurance, investor-grade information, and governance of ESG issues.
• 33:20 - Materiality. Val and Kyle explain how to consider materiality in the context of non-financial disclosure.  
• 37:57 - Broader disclosures and phasing. Andreas, Kyle, and Val consider whether disclosures should encompass all of ESG. They also address whether private companies would benefit from similar guidance, and what the phasing of an ESG ecosystem project could look like. 
• 45:07 - Best practices and next steps. Jay explains how companies should stay accountable to ensure they include quality and reliable disclosures. Kyle and Val encourage market participants to provide feedback to start the conversation and what to expect as far as timing. 

Andreas Ohl is a partner in PwC's National Office focused on mergers and acquisitions under US GAAP and IFRS. Andreas is chairman of the Business Valuation Standards Board at the International Valuation Standards Council, is a member of the working group that authored the AICPA's in-process R&D guide, and has served as a member of the FASB's Valuation Resource Group. 

Kyle Moffatt is a partner in PwC's National Office where he consults with engagement teams and audit clients on SEC reporting matters. He joined PwC in April 2020 after spending almost 20 years with the SEC, most recently as Chief Accountant and Disclosure Program Director in the Division of Corporation Finance.

Valerie Wieman is PwC’s National Office Editor-in-chief. She manages the creation, development, and publication of our brand-defining thought leadership. She is also responsible for Viewpoint, our new digital information platform. 

Jay Sivakumaran is a director in PwC’s National Office. Prior to joining the National office, he served clients primarily in the consumer markets sector.

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