Lawrence A. Cunningham, George Washington University Law SchoolFollow
Stephen M. Stephen M. Bainbridge, University of California, Los Angeles (UCLA) - School of Law
Jonathan Berk, Stanford Graduate School of Business; National Bureau of Economic Research (NBER)
Sanjai Bhagat, University of Colorado at Boulder - Department of Finance
Bernard S. Black, Northwestern University - Pritzker School of Law
William J. Carney, Emory University School of Law
David J. Denis, University of Pittsburgh - Johnstown
Diane K. Denis, University of Pittsburgh - Katz School of Business
Charles M. Elson, University of Delaware - John L. Weinberg Center for Corporate Governance
Jesse M. Fried, Harvard Law School; European Corporate Governance Institute (ECGI)
Sean J. Griffith, Fordham University School of Law; European Corporate Governance Institute (ECGI)
Jonathan M. Karpoff, University of Washington - Michael G. Foster School of Business; European Corporate Governance Institute (ECGI)
F. Scott Kieff, The George Washington University Law School
Edmund W. Kitch, University of Virginia School of Law
Katherine Litvak, Northwestern Pritzker School of Law
Julia D. Mahoney, University of Virginia School of Law
Paul G. Mahoney, University of Virginia School of Law
Adam C. Pritchard, University of Michigan Law School
Dale A. Oesterle, Ohio State University (OSU) - Michael E. Moritz College of Law
Roberta Romano, Yale Law School; National Bureau of Economic Research (NBER); European Corporate Governance Institute (ECGI)
Todd J. Zywicki, George Mason University - Antonin Scalia Law School, Faculty; PERC - Property and Environment Research Center
Christina P. Skinner, University of Pennsylvania - The Wharton School

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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.

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