May 12, 2022
Public comments for the Securities and Exchange Commission’s sweeping climate risk disclosure proposal are due on June 17 — with major implications for banks and their clients. On the latest episode of the ABA Banking Journal Podcast — sponsored by IntraFi Network — ABA experts Mike Gullette and Joe Pigg discuss:
- The contours of the proposed disclosures and how they would work.
- Implications for non-public companies, including privately owned banks not registered with the SEC.
- Safe harbors proposed within the disclosures.
- The need to avoid unintended consequences from an emerging area of risk practice, particularly when applied to prudential supervision.
- The potential need for sophisticated modeling and expert consulting services to comply and the need for scalability for smaller SEC registrants.
A comment letter writing guide to help bankers write their own comments will be available on aba.com in the coming days.