How to Implement a Tangible and Practical ESG Strategy.
Christopher is a Partner with Crowe, a top ten global accounting and consulting firm. He assists companies, their boards, and their counsel with regulatory compliance, investigations, and other complex matters. Christopher has significant experience dealing with SEC, EPA and other regulatory issues. He also leads Crowe’s national ESG Center of Excellence and assist a wide variety of clients with ESG strategy, program implementation, and reporting requirements. He is a frequent speaker on the subject, most recently at the American College of Corporate Directors, the American Bar Association, and many other industry and professional organizations. He has been quoted in Forbes, the LA Times, and other media outlets.
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Financial Reporting & Regulatory Update, Third Quarter 2022
During the third quarter of the 2022 calendar year, the Financial Accounting Standards Board (FASB) issued three new proposals: one on investments in tax credit structures using the proportional amortization method, one on derecognition of long-duration contracts, and one on segment reporting. The board also made a significant decision on its forthcoming standard on reference rate reform.
On Oct. 7, 2022, the Securities and Exchange Commission (SEC) announced that, due to a technological glitch known to have occurred as early as June 2021, the comment period for 12 releases would be reopened for 14 days. The SEC did not receive certain comments and suggests stakeholders confirm that their original comment submission appears on the SEC’s website. The 12 affected releases include, among others, proposals on climate-related disclosures, cybersecurity risk governance disclosures, and special purpose acquisition companies.
The SEC also issued its draft strategic plan for comment. It also remarked on crypto assets; environmental, social, and governance matters; high-quality financial reporting and current rulemaking proposals; climate-related financial risks proposals; and the 20th anniversary of the Sarbanes-Oxley Act (SOX). It issued statements on the importance of auditor independence and ethical responsibility, the Public Company Accounting Oversight Board’s (PCAOB) agreement with China, and risks of single-stock exchange-traded funds, and it provided testimony before a House committee. The SEC amended the rules to implement inflation adjustments under the Jumpstart Our Business Startups Act (JOBS Act) and the proxy voting advice rules, adopted amendments to the whistleblower rules, and finalized the pay-versus-performance disclosure rules. The SEC also proposed changes to Treasury security clearing rules, private fund reporting, clearing agency governance, Financial Industry Regulatory Authority (FINRA) membership requirements, and the shareholder proposal rule.
In addition to publishing its draft five-year strategic plan, the PCAOB released observations from 2021 inspections, its annual broker-dealer inspection report, its 2022 inspection plan, and an audit committee resource. The PCAOB remarked on the 20th anniversary of SOX. The Center for Audit Quality (CAQ) released an analysis of climate-related disclosures in S&P 500 Form 10-Ks and issued the results of its first audit partner pulse survey.
Checklists for the effective dates of FASB Accounting Standards Updates (ASUs) and Governmental Accounting Standards Board (GASB) statements are provided in the appendix.