In late 2020, rumor had it that the Securities and Exchange Commission (SEC) under the Biden Administration would likely move to encourage or require more robust disclosure of environmental-social-governance (ESG) and climate-related risks.1 Therefore, it came as no surprise when the Acting Chair of the Securities and Exchange Commission (SEC), Allison Herren Lee, released a statement on February 24, 2021, directing the SEC s Division of Corporate Finance to focus on climate-related disclosure in public company filings.2 Although the statement did not apply to the municipal bond market, we have observed that the SEC s Office of Municipal Securities often follows suit after the Division of Corporate Finance releases guidance on risk disclosure matters. For example, on May 4, 2020, SEC Chairman Jay Clayton and Director of the Office of Municipal Securities Rebecca Olsen issued a statement encouraging municipal securities issuers and obligors to provide disclosure relating to the effect
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