Our SEC comment letter series continues this week with a discussion of emerging comment letter trends related to current economic events.
In this special episode, PwC partners discuss the requirements and judgments in the proposed SEC climate disclosure requirements.
The SEC climate disclosure proposal continues to be a key topic of conversation as companies work through readiness assessments and contemplate process implementations.
This week, Heather Horn was joined by Valerie Wieman, a partner in PwC’s National Office, to revisit the proposal and talk through some of the most frequently asked questions we receive.
In this episode, you’ll hear them discuss:
  • 1:49 - The level of granularity called for in the proposed Regulation S-K disclosures by location
  • 4:38 - The proposed disclosure requirements for board member oversight and climate expertise
  • 8:38 - What companies need to disclose when adopting a transition plan if climate risks are not material
  • 10:34 - How the GHG Protocol and the SEC proposal call for different boundaries
  • 16:07 - How companies should report GHG emissions for less than wholly-owned consolidated subsidiaries (whether existing or newly-acquired)
  • 22:24 - The disclosure requirements for Scope 3 emissions by category
  • 24:05 - Severe weather baselines in financial statement disclosures and the prohibition of climate impact netting
  • 27:44 - How to assess what to disclose as a transition activity cost
Want to learn more about the SEC’s climate disclosure proposal? Listen to the audio version of our In the loop summarizing the key requirements, and read PwC’s comments on the proposal.
About our guest
Valerie Wieman is PwC’s National Office Editor-in-chief. She is involved in the creation, development, and publication of our brand-defining thought leadership, with a focus on ESG reporting. Prior to this role, she was part of PwC’s National Office SEC Services group, helping clients navigate SEC rules and regulations.
About our host
Heather Horn is PwC’s National Office thought leader, responsible for developing our communications strategy and conveying firm positions on accounting and financial reporting matters. She is the engaging host of PwC’s accounting and reporting weekly podcast and quarterly webcast series. With over 30 years of experience, Heather’s accounting and auditing expertise includes financial instruments and rate-regulated accounting.
Transcripts available upon request for individuals who may need a disability-related accommodation. Please send requests to us_podcast@pwc.com.

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