Guest post by Gayle S. Koch of The Brattle Group

Many parties from the investment, legal, regulatory, industrial, insurance, accounting and environmental communities have been calling for a consistent, comprehensive approach to financial climate change disclosure.  Some argue that disclosures may be required now due to:

1. Current state and regional regulation, and the portent of federal regulation related to climatechange and greenhouse gas emissions;
2. Ongoing and likely climate change-related litigation;
3. The commitment of significant corporate capital and management attention to develop climate change-related strategies and responses; and
4. Increasing investor demand for climate change disclosures.

For the past year, ASTM International’s Climate Risk Management Group has been working on a draft voluntary standard for financial climate change disclosures.  The ASTM standard would not supersede existing SEC and FASB requirements, but rather provides additional guidance relevant to climate change disclosures.  Three principles of the draft standard are:

• The standard is designed to address uncertainties to the extent feasible, through
• recognizing reasonable scenarios and ranges.
• Subsequent disclosures or changes to prior disclosures should not be construed as determining that the prior disclosures were inappropriate.
• The cost of disclosures should be balanced against the usefulness of the information presented.

To see The Brattle Group’s recent newsletter summarizing the new draft standard, and to obtain information on how to submit comments on the draft, click here.

Comments on the draft standard are due by February 2, 2009.  All interested parties should take advantage of this opportunity to review and comment on this draft.

In addition, the draft standard will be discussed on December 4, 2008 (noon-1:30 EST), when the American Bar Association conducts a teleconference on the subject sponsored by the Section of Environment, Energy, and Resources’ Environmental Disclosure Committee.  To obtain more information on this teleconference and instructions on how to register, click here.

For further information about this topic, please contact Akin Gump.