Endangered Green Reports:"Cumulative Materiality" in Corporate Environmental Disclosure After Sarbanes-Oxley
Editor's Summary: This Article describes the current state of the U.S. Securities and Exchange Commission's financial reporting requirements of corporate environmental liabilities and risks. The difficulty in quantifying these liabilities to meet the "materiality" standard under the Sarbanes-Oxley Act has led to a proposal by the American Society of Testing and Materials (ASTM) to cumulatively assess the financial impact of a company's environmental liabilities. The author advocates adoption of the ASTM's cumulative materiality standard as a more uniform, consistent benchmark instead of the current use of voluntarily published green reports. This Article is reprinted from the Harvard Journal on Legislation.