Client Alert

| February 8, 2010

SEC Offers Guidance on Climate Change-Related Disclosure

On January 27, 2010, the Securities and Exchange Commission (“SEC”) voted 3-to-2 to provide public companies with guidance on disclosure requirements with respect to climate change. Several of the SEC Commissioners and the Staff emphasized that the interpretive release, “Commission Guidance Regarding Disclosure Related to Climate Change,” does not amend the rules regarding companies’ reporting obligations, nor does it redefine existing standards of materiality. As Chairman Mary Schapiro stated, the release is intended to “provide clarity and enhance consistency” for public companies and the investor community.

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