Turner Commodities Law, PLLC
6353 Richmond Avenue, Suite 122
Houston, Texas 77057
(713) 899-5027
paul.turner@turnercommoditieslaw.com
3
• Identify key data gaps and close only those that matter.
• Prepare a standardized disclosure packet— a concise, defensible summary of governance, risks,
and (where requested) emissions intensities to streamline responses to banks, insurers, or global
traders.
• Monitor political and regulatory timing— including potential SEC revival, CSRD
extraterritorial effects on US exporters, and California implementation. Directive (EU)
2022/2464 (CSRD) European Sustainability Reporting Standards (ESRS E1).
Bottom Line
The SEC’s climate disclosure rule remains fully promulgated, formally effective, substantively
unenforced, and procedurally suspended. For energy traders and corporates, the smart move is to
maintain lean, credible processes that keep the organization ready for either regulatory revival or
counterparty-driven escalation.
6353 Richmond Avenue, Suite 122
Houston, Texas 77057
(713) 899-5027
paul.turner@turnercommoditieslaw.com
3
• Identify key data gaps and close only those that matter.
• Prepare a standardized disclosure packet— a concise, defensible summary of governance, risks,
and (where requested) emissions intensities to streamline responses to banks, insurers, or global
traders.
• Monitor political and regulatory timing— including potential SEC revival, CSRD
extraterritorial effects on US exporters, and California implementation. Directive (EU)
2022/2464 (CSRD) European Sustainability Reporting Standards (ESRS E1).
Bottom Line
The SEC’s climate disclosure rule remains fully promulgated, formally effective, substantively
unenforced, and procedurally suspended. For energy traders and corporates, the smart move is to
maintain lean, credible processes that keep the organization ready for either regulatory revival or
counterparty-driven escalation.
