The New York State Department of Financial Services ("NYDFS") urged the SEC "to act without delay in its climate change disclosure rulemaking." In response to the SEC's request for public comment on climate risk disclosure, NYDFS recommended that such disclosures:
- be "reliable, balanced, understandable, consistent over time, comparable among institutions within a sector, and provided in a timely manner";
- include corporate governance, board oversight of climate-related issues, the impact on business strategy and processes for risk management;
- include policies and procedures relating to climate risk for those regarding corporate governance;
- take a proportionate approach reflective of an institution's scale, size and complexity; and
- avoid over-reporting and ease the cost of compliance.
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