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Sullivan & Cromwell Discusses the Implications for Financial Institutions of Proposed SEC Climate Disclosure Rules

Reynolds Holding

Fiscal year 2027 (filed in 2028). ( [1] ) Assumes a fiscal year end of December 31. 6] See Sullivan & Cromwell, Financial Stability Oversight Council Report on Climate-Related Financial Risk (Nov. 7] CFTC, Climate-Related Market Risk Subcommittee, Managing Climate Risk in the U.S.

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