The IMA Financial Reporting Committee (FRC or Committee) issued a comment letter in response to the SEC’s Request for Public Input, Climate Change Disclosures.

In its comment letter, the FRC raises several points for the SEC to consider in evaluating movement on regulation over climate-related financial disclosures. These points include maintaining the current definition of materiality, supporting a single principles-based framework, developing internal controls, requiring ESG disclosures with a different timing than for currently required filings, and applying current safe-harbor provisions over forward-looking information. In addition, the Committee believes that climate-related reporting is not yet adequately mature to require third-party assurance.

The FRC response supplements the comment letter issued by IMA.