For years, the SEC has been talking about requiring some sorts of climate disclosures. By late spring of 2022, it looked as though the agency would finally do it and then came the proposed rule that was open for comments. And, wow, did they come.

More than 10,000 individuals and organizations weighed in, according to the Real Estate Roundtable, including many from commercial real estate.

For example, the CRE Finance Council, among other things, criticized a potential adoption period for the new rule of December 2022. "Given the breadth and depth of the proposed requirements, a year-end adoption date is very aggressive," the group wrote. "For context, the Partnership for Carbon Accounting Financials ("PCAF"), a framework cited by the SEC in the Proposed Rule, has a three-year implementation period for organizations that opt-in to the program. CREFC believes that the final rule should be subject to a longer implementation period to allow market participants to continue to develop best practices over time."