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Sullivan & Cromwell Discusses the Implications for Financial Institutions of Proposed SEC Climate Disclosure Rules

Reynolds Holding

These metrics would then be subject to audit by an independent registered public accounting firm and come within the scope of the institution’s internal control over financial reporting. 24] CDP, Finance sector’s funded emissions over 700 times greater than its own (April 28, 2021), available at [link]. [25] at 87-91. [27]

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