ESG Investment Practices
Summary
SIFMA provided comments to the U.S. Securities and Exchange Commission (SEC) on their proposal to enhance disclosures by certain investment advisers and funds about their environmental, social and governance (ESG) investment practices.
Excerpt
August 16, 2022
Submitted electronically via SEC.gov
Vanessa Countryman, Secretary
Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549-1090
Re: File No. S7-17-22
Enhanced Disclosures by Certain Investment Advisers and Investment Companies about Environmental, Social, and Governance Investment Practices
Dear Ms. Countryman:
On behalf of our member firms and their customers, the Securities Industry and Financial Markets Association (“SIFMA”)1 appreciates the opportunity to comment on the Commission’s proposal2 to enhance disclosures by certain investment advisers and funds about their environmental, social and governance (“ESG”) investment practices (the “Proposal”).
SIFMA lauds the Commission for its attempt to provide investors in ESG investment products with clear, accurate and comparable information, and supports the Commission’s decision to focus on using disclosures to clarify the role ESG factors play in managers’ investment decisions instead of mandating a single definition of “ESG.”
We note that SIFMA Asset Management Group of SIFMA (“SIFMA AMG”) has filed a letter detailing various possible improvements to the Proposal. In addition to the items raised in that letter, SIFMA believes certain provisions of the Proposal should be modified to maintain the goals of the Proposal while limiting unintended or undue consequences. We submit the following suggested revisions and alternative approaches to portions of the rule for the Commission’s consideration.
1 SIFMA is the leading trade association for broker-dealers, investment banks and asset managers operating in the U.S. and global capital markets. On behalf of our industry’s nearly 1 million employees, we advocate for legislation, regulation and business policy, affecting retail and institutional investors, equity and fixed income markets and related products and services. We serve as an industry-coordinating body to promote fair and orderly markets, informed regulatory compliance, and efficient market operations and resiliency. We also provide a forum for industry policy and professional development. SIFMA, with offices in New York and Washington, D.C., is the U.S. regional member of the Global Financial Markets Association (GFMA). For more information, visit http://www.sifma.org. SIFMA appreciates the assistance of George B. Raine, James D. McGinnis, Jennifer Choi and Colton Canton of Ropes & Gray LLP in the preparation of this response.
2 Enhanced Disclosures by Certain Investment Advisers and Investment Companies about
Environmental, Social, and Governance Investment Practices Release No. IA-6034, 87 Fed. Reg. 36654 (proposed May 25, 2022), available at https://www.sec.gov/rules/proposed/2022/ia-6034.pdf [hereinafter the “Proposal” or “Proposing Release”].