- Comment letters aligned with the SEC staff’s September 2021 illustrative comment letter (we reported on here) were sent to 104 reporting entities—primarily traditional companies, as opposed to “Investment Entities” (funds, trust, or vehicles solely focused on investing in other companies or assets).
- Most of the comment letters aligned with the illustrative comment letter were issued in September 2021, or May through September 2022, and no additional letters have been issued since October 2022.
- Half of the recipients of comment letters aligned with the illustrative comment letter received between six and eight comments.
- By category (based on the nine numbered topics in the illustrative comment letter), the physical effects of climate change garnered the most comments, as shown here:
Nearly two-thirds of the recipients of comment letters aligned with the illustrative comment letter were in the Energy & Transportation or Manufacturing industries, as shown here:
A plurality (42%) of recipients of comment letters aligned with the illustrative comment letter were large- or mega-cap companies, while nearly one-third had market caps between $1 billion and $10 billion.
Greenwashing-only comment letters were sent to 167 reporting entities—primarily Investment Entities as opposed to traditional companies. Most of the greenwashing-only letters were issued between July and October 2021, although such comments have continued to trickle out during the entire period reviewed.