Sullivan & Cromwell Discusses the Implications for Financial Institutions of Proposed SEC Climate Disclosure Rules
Reynolds Holding
APRIL 21, 2022
Financial institutions that are large accelerated filers could be required to begin capturing emissions information (other than Scope 3 emissions) as early as January 2023 and Scope 3 emissions metrics as early as January 2024. Compliance with the proposed rules would be phased in (see Appendix A for disclosure compliance dates). BACKGROUND.
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