News

CREFC to Comment on SEC’s Climate Disclosure Proposal

March 28, 2022

As covered last week, on March 21, the Securities and Exchange Commission (SEC) released a long-awaited climate disclosure proposal. Please see here for a Fact Sheet: Enhancement and Standardization of Climate-Related Disclosures. The comment period will remain open for 30 days after publication in the Federal Register or May 20, whichever period is longer. CREFC is reviewing the proposal closely and plans to file comments.

Our response will incorporate the work of the Transparency Committee housed under CREFC’s Sustainability Initiative, which is evaluating the climate-related data that can and should be incorporated into CREFC’s Investor Reporting PackageTM (IRPTM). We will also address the questions raised by the SEC regarding asset-backed issuers.

Notably, and as stated on page 292 of the proposal:

The proposed rules would not apply to asset-backed issuers. The Commission and staff are continuing to evaluate climate-related disclosures with respect to asset-backed securities.

The SEC specifically asks if they should require asset-backed issuers to provide some or all of the proposed Regulation S-K disclosures. They also request feedback on other types of climate disclosures that might be “better suited” to asset-backed issuers, and if such disclosures should be “tailored to various asset classes.”

Please contact Sairah Burki if you would like to join the Sustainability Initiative and the working group responding to the Proposal.

Contact

Sairah Burki
Managing Director, Regulatory Affairs & Sustainability
703.201.4294
sburki@crefc.org
Our response will incorporate the work of the Transparency Committee housed under CREFC’s Sustainability Initiative, which is evaluating the climate-related data that can and should be incorporated into CREFC’s Investor Reporting PackageTM (IRPTM).
The information provided herein is general in nature and for educational purposes only. CRE Finance Council makes no representations as to the accuracy, completeness, timeliness, validity, usefulness, or suitability of the information provided. The information should not be relied upon or interpreted as legal, financial, tax, accounting, investment, commercial or other advice, and CRE Finance Council disclaims all liability for any such reliance. © 2022 CRE Finance Council. All rights reserved.

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