A Convergence of Risk Disclosure

risk assessments

Like many other people, last week I read the SEC’s new requirements for disclosure of climate change risks with a sense of trepidation. The more I studied them, however, the more I felt something else: a sense of déjà vu.  Like, has anybody else noticed how similar these disclosure requirements are to those that the…

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SEC Adopts Climate Disclosure Rule

climate

The Securities and Exchange Commission has finally adopted its rule for disclosure of greenhouse gas emissions and climate risks, voting Wednesday to impose the rule but dropping its original (and most controversial) proposal that companies would need to calculate and report greenhouse gasses caused by their supply chains. The vote fell along the SEC’s usual…

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SEC Climate Rule Coming Next Week

climate

The Securities and Exchange Commission has scheduled a vote on its proposed climate-change disclosure rule for next week, amid rumors that the agency will drop its original idea to have companies track and report the carbon emissions of their supply chains. The meeting will happen next Wednesday, March 6, at 9:45 a.m., and will be…

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SEC Kicks Climate Rule to 2024

climate

The Securities and Exchange Commission has pushed adoption of its greenhouse gas disclosure rule to April 2024, confirming what everybody already knew: the agency’s progress on a final text is mired in debate about how to handle greenhouse gas emissions from a company’s supply chain. The Biden Administration published its Fall 2023 regulatory agenda on…

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A Memo on Cyber Materiality

SolarWinds

So there I was the other day, pondering that new Securities and Exchange Commission rule for expanded disclosure of cybersecurity issues, when my phone rang. It was my friend the cybersecurity auditor. “Hey,” he said, “I have an idea for how companies can prepare for that new rule about disclosing cybersecurity stuff.”  I was intrigued.…

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SEC Warns on Risk Assessments

risk assessments

The top accountant at the Securities and Exchange Commission is warning auditors and corporations alike to do better at risk assessments, and in particular to pay more attention to small control failures that might be suggestive of larger issues in a company’s control environment. Chief accountant Paul Munter released his statement Friday afternoon, a maneuver…

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SEC Adopts Cyber Disclosure Rule

qualitatively material

As expected, the Securities and Exchange Commission adopted new rules today requiring publicly traded companies to make more disclosures about the cyber risks they have and the specific cyber attacks they suffer.  The final rules are largely in step with what the SEC first proposed last year: annual discussion of cyber risks in the company’s…

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SEC to Vote on New Cyber Rules

SolarWinds

The Securities and Exchange Commission will, at long last, vote next Wednesday on new rules that would require companies to make expansive new disclosures about their cybersecurity risks and the cyber incidents they suffer. The SEC originally proposed the rules in March 2022 — and they have been a sleeper issue in SEC rulemaking while…

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Here Come the Clawback Clauses

clawbacks

The Securities and Exchange Commission enacted a rule today that will require public companies to adopt and disclose executive compensation clawback policies, echoing the Justice Department’s effort to make companies exercise clawbacks more often when their executives commit misconduct. The rule directs U.S. stock exchanges to update their listing standards so that listed companies are…

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SEC to Auditors: Do Better on Fraud Risk

fraud

The Securities and Exchange Commission is urging auditors to do better at assessing fraud risk among their clients — a rather notable statement peppered with keywords such as “gatekeepers” and “protection of investors,” clearly intended to warn audit firms that the agency wants to see improvement here. The statement came on Tuesday from Paul Munter,…

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