After a long meeting, the SEC in a divided vote passed its long-expected greenhouse gas disclosure rule. While it changed "quite significantly" from the original more extensive form, as Anna Pinedo, a partner with law firm Mayer Brown, tells GlobeSt.com, there is still significant implications for CRE.

Perhaps the biggest simplification in the new version is the lack of demand for Scope 3 emissions, or those attributable to supply chains. Scope 1 emissions (directly generated by a company) and Scope 2 (created by electricity, heat, cooling, and other services the company uses) remain in place. They have to be material in nature.

"Larger commercial real estate companies that are public to start, and the commercial REITs, as well as potentially the REITs that own interest in commercial real estate, whether in CMBS or another format," are likely to be immediately responsible for additional reporting, disclosures, and financial statement requirements, says Pinedo. So-called large accelerated filers (companies with public float — shares in the hands of public investors — of more than $700 million) and accelerated filers (public float over $75 million and under $700 million, with annual revenue of more than $100 million) will also have to provide an assurance report from an independent provider.