On March 6, 2024, the Securities and Exchange Commission (SEC) adopted by a 3-2 vote a series of new and extensive disclosure rules that will require all registered companies, including FPIs, to include detailed climate-related information in their registration statements and periodic reports, and climate-related financial statement metrics in a note to their audited financial statements. Following the rule’s initial proposal in March 2022, the SEC received a record-setting 24,000+ comment letters and has spent the intervening period considering key aspects of the proposed rules, particularly with respect to disclosure metrics and requirements for GHG emissions.

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