Comment Letter on SEC Climate Disclosure Proposal by CohnReznick

It’s well known that the SEC’s pending climate disclosure rule stoked a great deal of debate, particularly concerning the costs and benefits and questions of the SEC’s authority. Equally important are some less dramatic but more profound practical concerns about the rule’s auditing requirements. 

Consider the views on this topic of CohnReznick, a national accounting firm with an SEC audit practice consisting of middle-market public companies. CohnReznick supports the SEC’s objective to bring about consistent, comparable and reliable information to investors to enable them to make informed judgments about the material impacts of climate-related risks and mitigation activities of SEC issuers.

However, the firm also expresses concerns related to the integrity and auditability of information that the proposal envisions be included in the scope of SEC issuers’ annual audited financial statements pursuant to Regulation S-X. The firm encourages the SEC to consider alternative placement of such disclosures and reduction of their granularity. 

Read the firm’s thoughtful comment letter here, on our Across The Board Resources page.