Disclosure Resources

Disclosure articles

Analyses and guidance on disclosure

• Progress Report, by the Advisory Committee on Improvements to Financial Reporting to the United States Securities and Exchange Commission, February 2008.
• Being Underway, Not in Delay, on Climate Change-Related Disclosure, by Raymond R. Rose, Environmental Claims Journal, Vol. 20, No. 1, 23-38, January 2008.
• Paying More for 404, by Alix Stuart, CFO.com, January 29, 2008.
• Who Could Get Sued for Global Warming?, by Steve Hargreaves, CNN.com, January 9, 2008.
• Whose Carbon Footprint Is Too Big for Their Corporate Boot?, by Beth Young, from The Corporate Library, December 7, 2007.
• Ready or Not, Here Comes Fair Value, by Sarah Johnson, CFO.com, October 17, 2007.
• Will the SEC Go Green?, by Marie Leone, CFO.com, September 19, 2007.
• New York Subpoenas 5 Energy Companies, by Felicity Barringer and Danny Hakim, New York Times, N.Y./Region Section, Online Edition, September 16, 2007.
• Environmental Disclosure Due Diligence: Taking the Next Step in Environmental Due Diligence, by C. Gregory Rogers, presented at 36th Conference on Environmental Law, Keystone, CO, March 8-11, 2007.
• FIN 47 Poses Hard Questions for Estimating Future Environmental Liabilities, Goodwin Proctor, Environmental & Energy Advisory, April 24, 2007.
• Dialogue: Deciphering and Applying Critical Terms under FAS 143 and FIN 47—'Normal Operations' and 'Associated with Asset Retirement', edited by Scott Deatherage, ABA, Special Committee on Environmental Disclosure Newsletter, Vol. 3, No. 2, 1-22, July 2006
• The Impact of FIN 47 (So Far), by the Controller's Leadership Roundtable, Corporate Executive Board, March 2006
• FIN 47: The Future is Now, by Marie Leone, CFO.com, February 6, 2006.
• A Quantitative Assessment of Internal Controls: Internal Auditors Can Fortify Their Assurance Efforts by Implementing a Systematic, Framework-Based Approach to Control Reviews, by William E. Perry and H.C. Warner, Internal Auditor, April 2005.
• Corporate Environmental Disclosures: Old Complaints, New Expectations, by Kevin A. Ewing, Jason B. Hutt, and Erik E. Petersen, ABA, Special Committee on Environmental Disclosure Newsletter, Vol. 2, No. 2, 2-15, May 2005.
• Financial Reporting of Environmental Liabilities and Risks after Sarbanes-Oxley, by C. Gregory Rogers, Hoboken, New Jersey: John Wiley & Sons, Inc., 2005

Petitions and letters to SEC on disclosure

• Letter Request from Senators Christopher J. Dodd and Jack Reed, U.S. Senate, to Christopher Cox, Chairman, U.S. Securities and Exchange Commission, December 6, 2007. (Asking SEC for interpretive guidance for corporate disclosure on climate change.)
• Petition for Interpretive Guidance on Climate Risk Disclosure, Letter Petition from Investors to the U.S. Securities and Exchange Commission, September 18, 2007. (Asking SEC for interpretive guidance for corporate disclosure on climate change.)
• Letter Petition from Investors to John W. White, Director, Division of Corporation Finance, U.S. Securities and Exchange Commission, September 18, 2007. (Asking SEC to review the adequacy of corporate disclosure on climate change.)
• Minutes of the March 9, 2005 Board Meeting: Potential Agenda Project on the Reconsideration of the Accounting for the Contingent Environmental Liabilities under Statement 5, by Duke (no first name given), Memorandum to Board members, Financial Accounting Standards Board, March 15, 2005.
• Letter Request from Jill Ratner, President, Rose Foundation for Communities and the Environment to Jonathan G. Katz, Secretary, U.S. Securities and Exchange Commission, September 20, 2002. (Asking SEC for two new rules to clarify environmental disclosure requirements.)

Enforcement and tracking of disclosure

• Recent SEC Enforcement Proceedings—Environmental Reserves, Sidley Austin, Environmental Update, July 13, 2007.
• Recent SEC Enforcement of Environmental Financial Disclosure, E. Lynn Grayson, Jenner & Block, Land, Air and Water News, July 26, 2007.
• SEC Enforcement Action Shines Light on Environmental Disclosures, by Lewis B. Jones and John C. Bottini, The Metropolitan Corporate Counsel, April 2007.
• SEC Enforcement Declines 8.9 Percent, by Sarah Johnson, CFO.com, November 3, 2006.
• 2006 SEC Envorcement Activitiy Lags, by Greg Farrell, USA Today, Money Section, Online Edition, August 20, 2006.
• $284 Million Ends Safety-Kleen Lawsuit, by Dave Cook, CFO.com, Today in Finance Section, April 27, 2005.
• Environmental Disclosure, SEC Should Explore Ways to Improve Tracking and Transparency of Information, by the Government Accountability Office (GAO), Report to Congressional Rrequestors, GAO-04-808, July 2004.
• Guidance on Distributing the 'Notice of SEC Registrants' Duty to Disclose Legal Environmental Legal Proceedings in EPA administrative enforcement actions', by Mary Kay Lynch, Director, Office of Planning and Policy Analysis, Office of Enforcement and Compliance Assurance, U.S. Environmental Protection Agency, Letter to OECA Office Directors, January 19, 2001.
• U.S. EPA Notifying Defendants of Securities and Exchange Commission's Environmental Disclosure Requirements, Office of Regulatory Enforcement, Enforcement Alert, Vol. 4, No. 3, EPA-300-N-01-008, October 2001

Relationships in disclosure, performance, value, and risk

• Building Value by Paring Environmental Risk, by C. Gregory Rogers, Financial Executive, September 2007.
• Is CEO Certification of Earnings Numbers Value-Relevant?, by Utpal Bhattacharya, Peter Groznik, and Bruce Haslem, from the Social Science Research Network (SSRN), December 2006.
• Revisiting the Relation Between Environmental Performance and Environmental Disclosure: An Empirical Analysis, by Peter M. Clarkson, Yue Li, Gordon D. Richardon, and Florin P. Vasvari, from the Social Science Research Network (SSRN), April 5, 2006.
• Essays on Disclosure, by Robert E. Verrecchia, Journal of Accounting and Economics, vol. 32, pp. 97-180, 2001.
• Discretionary Disclosure, by Robert E. Verrecchia, Journal of Accounting and Economics, vol. 5, pp. 179-194, 1983.