SEC Commissioner Lee on Myths and Misconceptions about “Materiality”

SEC Commissioner Allison Herron Lee made a very significant speech about the materiality of ESG disclosures:

[A]s debates around climate and ESG disclosure have intensified, I have found through dozens if not hundreds of conversations that a number of misconceptions about materiality – what it is and what it is not – have proliferated. For example, many appear to believe that materiality currently works almost preternaturally, on its own with no need for regulatory involvement, to produce all important information from all public companies at all times. Many have also come to believe (incorrectly) that the SEC is legally prohibited from requiring specific disclosures unless it can demonstrate that each such disclosure is individually material to the bottom line of every public company.

SEC.gov | Living in a Material World: Myths and Misconceptions about “Materiality

She dispels myths that current rules are adequate to give investors all relevant information and that such standards that do exist are being met. Most important, she refuted the myth that climate and ESG are matters of social or “political” concern, and not material to investment or voting decisions.” This speech is thoroughly documented and a clear indication of the Commission’s future direction.

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