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The SEC’s Interpretive Release on Climate Change Disclosure

Jeffrey A. Smith, Matthew Morreale, Kimberley Drexler


ear stalemate, on 27 January 2010, the U.S. Securities and Exchange Commission (SEC) voted three-to-two to issue an Interpretive Release on disclosure requirements relating to climate change. The decision took climate change, which was a much-debated topic on the sidelines of required disclosure, into the mainstream of disclosure issues. It also revealed some sharp divisions among the commissioners on whether the SEC’s action was appropriate or necessary. The Release was published on 2 February 20101 and highlights four possible sources of


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