Note: Subsequent to publishing our client alert, at least four lawsuits have been filed in federal courts challenging the SEC’s final climate risk disclosure rule. On Friday, March 15th, a three-judge panel for the U.S. Court of Appeals for the Fifth Circuit granted a motion for an administrative order temporarily staying the effectiveness of the agency’s final rule. As predicted in our alert, litigation over the final rule is expected to be lengthy and it is impossible to know when such litigation will be concluded.