On Friday, October 7, the Securities and Exchange Commission (SEC) reopened the public comment period for eleven proposed rules whose comment periods closed after March 21, 2022. This includes the proposed climate-related disclosures for investors. Additional analysis of the potential impact of these proposed rules can be found here. In reopening the rules, the SEC stated that a technological error resulted in some comments not being received through the SEC’s web form. Anyone who submitted a comment on the climate-related disclosures, or one of the other affected rules, is encouraged to ensure that their comments are posted on the SEC’s public website. The new comment period will remain open for 14 days after the SEC republishes the rules in the Federal Register. So far, thousands of comments have been received on the proposed climate-related disclosure requirements.

The SEC proposed rules that are being reopened for additional comments include:

• Reporting of Securities Loans, Release No. 34-93613 (Dec. 8, 2021)


• Prohibition Against Fraud, Manipulation, or Deception in Connection with Security-Based Swaps; Prohibition against Undue Influence over Chief Compliance Officers; Position Reporting of Large Security-Based Swap Positions, Release No. 34-93784 (Feb. 4, 2022)


• Money Market Fund Reforms, Release No. IC-34441 (Feb. 8, 2022)


• Share Repurchase Disclosure Modernization, Release Nos. 34-93783, IC-34440 (Feb. 15, 2022)


• Short Position and Short Activity Reporting by Institutional Investment Managers, Release No. 34-94313 (Mar. 16, 2022); see also Notice of the Text of the Proposed Amendments to the National Market System Plan Governing the Consolidated Audit Trail for Purposes of Short Sale-Related Data Collection, Release No. 34-94314 (Mar. 16, 2022)


• Cybersecurity Risk Management, Strategy, Governance, and Incident Disclosure, Release Nos. 33-11038, 34-94382, IC-34529 (Mar. 23, 2022)


• Private Fund Advisers; Documentation of Registered Investment Adviser Compliance Reviews, Release No. IA-5955 (Mar. 24, 2022)


• The Enhancement and Standardization of Climate-Related Disclosures for Investors Release Nos. 33-11042, 34-94478 (Apr. 11, 2022)


• Special Purpose Acquisition Companies, Shell Companies, and Projections, Release Nos. 33-11048, 34-94546, IC-34549 (May 13, 2022)


• Investment Company Names, Release Nos. 33-11067, 34-94981, IC-34593 (June 17, 2022)


• Enhanced Disclosures by Certain Investment Advisers and Investment Companies About Environmental, Social, and Governance Investment Practices, Release Nos. 33-11068, 34-94985, IA-6034, IC-34594 (June 17, 2022)


• Request for Comment on Certain Information Providers Acting as Investment Advisers, Release Nos. IA-6050, IC-34618 (June 22, 2022)

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