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Lawrence A. Cunningham, Stephen M. Bainbridge, Jonathan Berk et al., The SEC'S Misguided Climate Disclosure Rule Proposal, 41 Banking & Fin. Servs. Pol'y Rep. 1 (2022).

Abstract: The following article adapts and consolidates two comment letters submitted last spring by a group of twenty-two professors of finance and law on the SEC's proposed climate change disclosure rules. The professors reiterate their recommendation that the SEC withdraw its proposal as legally misguided, while outlining some of the issues that the proposal will face when challenged in court.