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SEC Proposed Climate Disclosure: Verification

An aspect of the proposed climate disclosure rule released by the U.S. Securities Exchange Commission on March 21, 2022 focuses on "attestation" requirements in the proposed rule for Scope 1 and Scope 2 GHG emission disclosures.  This is a verification of emissions requirement by a third party and the SEC is actively seeking input on how to establish independence of that third party - speak now, those who will have to attest.

With respect to the issue of “impairment” of a third party provider’s independence, the SEC is requesting comment on whether it should simply require that the third-party be independent according to the standard under 1505(b), or some other standard, or alternatively whether the agency should develop new guidance on what constitutes impairment