More climate disclosure requirements are on the horizon for energy producers and energy consumers. The Securities and Exchange Commission (SEC) is thinking about imposing a one-size fits all requirement for publicly-traded and in some cases even private companies to issue assessments of how climate change will impact the companies. Issuers, lawyers, securities analysts, banks—well, just about everyone, is wondering what this may mean and how a new disclosure regime would look.

President Biden has announced a goal of reducing the emissions of U.S. greenhouse gases to 50% of the emissions in 2005. The administration is following the early Obama administration game plan of trying to close off domestic production of hydrocarbons with implicit assumption that such actions will eliminate consumption of hydrocarbons through a suite of regulatory

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