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September 23, 2021

Comments to the Commodity Futures Trading Commission on the proposed creation of a carbon markets subcommittee of the Energy and Environmental Markets Advisory Committee

The following is an edited comment letter that was submitted to the Commodity Futures Trading Commission (CFTC, or Commission) on September 22nd for the invitation to comment on the proposal by the Commercial Energy Working Group to form an EEMAC carbon markets subcommittee.[1] The proposed stakeholder group would produce a report on principles for designing Continue Reading »

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August 21, 2021

Where the Rubber Meets the Road: How Can an SEC Climate Risk Disclosure Rule Survive Cost-Benefit Analysis?

Mario Olczykowski and Lee Reiners In a recent post, we summarized comments submitted to the Securities and Exchange Commission (SEC or Commission) regarding the request for public input on climate change disclosures (RFPI) released by then Acting Chair, Allison Herren Lee on March 15, 2021. With the Commission set to release a Notice of Proposed Continue Reading »

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July 9, 2021

Summary of Comment Letters for the SEC’s Climate Risk Disclosure RFI

Mario Olczykowski and Lee Reiners Recognizing that “investor demand for, and company disclosure of information about, climate change risks, impacts, and opportunities has grown dramatically,” former Securities and Exchange Commission (SEC or Commission) Acting Chair Allison Herren Lee released 15 questions for consideration on March 15, 2021 “with an eye toward facilitating the disclosure of Continue Reading »

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