In March 2022, the SEC issued a proposal (Proposal) for rules (Rules) that would require public companies to disclose certain climate-related information. In a recent Sullivan & Cromwell program, partners Catherine M. Clarkin, Robert W. Downes, Sarah P. Payne and Marc Treviño, as well as senior policy advisor and counsel – and former SEC Chair – Jay Clayton, analyzed the Proposal’s content and the possible impact of the Rules on public companies as well as private fund managers. This second article in our two-part series discusses the broad implications of the Proposal; key challenges and timing; and the anticipated pushback. The first article covered the five key elements of the Proposal. See “Fireside Chat With SEC Chair Gensler: Three Key Disclosure Areas (Part One of Two)” (Nov. 18, 2021); and “Acting SEC Chair Outlines Commission’s Approach to ESG” (Apr. 1, 2021).