Understanding the SEC’s Proposed Climate Rule: Part 2
Taylor Pullins, an attorney and adjunct professor at Columbia University’s Sustainability Management Program, will teach “Understanding the SEC Rules: Non-Attorney Disclosure Laws” this fall.
Earlier this year, Prof. steve cohen published a blog post Details potential updates to the SEC’s climate disclosure rules, and how Colombia’s climate disclosure rules will work MSc in Sustainability Management The program will accommodate this rule change by adding three new courses to the program’s elective list. These new courses—”SEC Climate Disclosure Compliance Management,” “Understanding SEC Rules: Non-Attorney Disclosure Law,” and “Climate Risk and Scenario Analysis”—are designed to help our students understand these Complexity and nuance of content. These proposed rules have important implications for future investments in a more sustainable world.
Sustainability Management (SUMA) staff and faculty have been working with professionals to design these courses to be as effective as possible. We reached out to the professors of these new courses so they could share their experiences and what they think these courses will offer following the proposed changes to the SEC guidance.We are sharing their responses Series of three blog posts This way you can get to know them better and learn about their new classes.
last week we ended up with Interview with Adjunct Professor Carolyn Kim Allwin. In part two of this series, we hear from Taylor Pullins and his new course, “Understanding SEC Rules: Non-Attorney Disclosure Law.”
Click here to read Part 1 and Part 3 (coming soon).
Taylor Pullins is a partner in the Global Environmental practice and head of the ESG and Sustainability practice at White & Case LLP. Many of his clients are from the energy industry.
Prince’s work involves the drafting and negotiation of environmental and indemnity clauses in complex commercial transactions, including mergers, acquisitions, divestitures, project finance and securities offerings. He has extensive experience advising clients on environmental permits, enforcement defense matters, environmental litigation, internal investigations, and a broad range of environmental/regulatory matters affecting clients’ operations. In addition, Prince assists clients in making complex policy and business decisions involving changing regulatory and societal expectations on climate change and other matters related to environmental, social and governance (ESG) practices.
All of these factors, and others, make him a perfect fit to teach this new course at SUMA.
What initially motivated you to pursue environmental law?
I grew up in the American West where water scarcity was a real concern. A constant reminder of the need to protect water resources is my introduction to environmental law and the principles of sustainable development. I was impressed with the impact of industrial wastewater discharges from the undergraduate classes around Lake Tahoe and the presentation of the “Keep Lake Tahoe Blue” campaign. I became very focused on learning more about the importance of responsible industrial operations and municipal planning.
The law school curriculum around environmental law has expanded and improved considerably since I was in school. Although the few courses I took introduced me to major federal environmental law, I didn’t understand what a career in environmental law would look like until I spent a summer at a law firm after my second year. It was a refreshing revelation to find an area of law that I personally had a strong interest in. Now, I play a direct role in helping clients not only comply with the law, but also operate and plan in a responsible and sustainable manner.
What impact do you think the proposed SEC climate disclosure guidelines will have?
The U.S. Securities and Exchange Commission has proposed changing rules for disclosing climate risks to public companies. When the final rules are released later this year, I predict they will be one of the most impactful rule changes of our lifetime. The normalization of climate risk disclosure should drive companies to implement improved business practices for managing climate and other environmental aspects.
What do you think the proposed guidelines mean for future investments in a greener world?
There will be winners and losers among public companies when it comes to the SEC’s climate disclosure rules. Since the SEC issued climate risk disclosure guidance in 2010, many companies have included limited information on the physical and transitional risks posed by climate change in their SEC filings. During the same period, companies have shared more information about their operations in sustainability reports.
Sustainability reports, which are not subject to the same regulatory scrutiny as SEC filings, tend to highlight positive aspects of a company’s environmental performance. In some ways, companies use sustainability reporting as part of their investor marketing efforts. With the publication of the final rules on climate risk disclosure, public companies will be required to provide more information on climate-related risks that may affect their business, operations or financial condition, including climate-related financial indicators that will be included in the disclosure. included in its audited financial statements. In other words, investors will get more information about how companies are managing climate change risks in SEC filings. As a result, investors will be better equipped than ever to make investment decisions that align with their environmental priorities.
How will your course help sustainability professionals navigate these new guidelines?
Once finalized, the SEC’s proposed rule on climate risk disclosure would constitute a landmark regulatory change. Sustainability professionals will benefit from a clear understanding of the public policy and corporate compliance drivers behind the rules. This course is designed to help sustainability professionals understand the intricacies of the rules. Starting with a foundation of administrative law principles that underpin the U.S. regulatory system, we analyze case studies that show how companies have historically handled climate disclosures and the changes that new rules require them to make. We will focus on areas that pose challenges for some sectors when demonstrating meaningful improvements in emissions performance. We will also provide a comparative analysis of climate and sustainability disclosure regulation in other major jurisdictions, including the EU.
Laura Millar is a Program Manager for Columbia University’s Sustainability Management and Sustainability Science Program.
