June 15, 2021

Sustainability Accounting Standards Board (SASB)
1045 Sansom Street, Suite 450
San Francisco, CA 94111

Submitted via SASB Online Comment Portal

Re: Proposed Changes to the SASB Asset Management & Custody Activities Standard – Invitation to Comment on Exposure Draft and Basis for Conclusions

To Whom It May Concern:

On behalf of the Asset Management Group of the Securities Industry and Financial Markets Association (“SIFMA AMG” or “AMG”)1, we appreciate the opportunity to comment on the proposed changes to the SASB Asset Management & Custody Activities Standard (the “Exposure Draft”).2 SIFMA AMG supports SASB’s continued efforts to develop industry specific sustainability accounting standards. We believe the SASB standards could provide the industry with a key reporting framework that could help facilitate better disclosure of material sustainability information to investors. In that light, SIFMA AMG supports the Exposure Draft’s proposed changes that would remove the “Systemic Risk Management” section from the SASB Asset Management & Custody Activities Standard.3

SIFMA AMG believes the Systemic Risk Management section includes outdated and disproven language that has been abandoned by all relevant regulatory bodies. The continued inclusion of the Systemic Risk Management section undermines the effectiveness of the Asset Management & Custody Activities Standard. We believe the section’s narrative and required disclosures are misaligned with current regulatory frameworks and confuse investors with information not relevant to sustainability. The SASB standards should only include disclosures with a clear connection to sustainability, and to that effect, SASB should continually evaluate their standards to ensure the required information is relevant. Removing the Systemic Risk Management section is a necessary step to optimize the efficacy of the SASB Asset Management & Custody Activities Standard.

1 SIFMA AMG brings the asset management community together to provide views on U.S. and global policy and to create industry best practices. SIFMA AMG’s members represent U.S. and global asset management firms whose combined assets under management exceed $45 trillion. The clients of SIFMA AMG member firms include, among others, tens of millions of individual investors, registered investment companies, endowments, public and private pension funds, UCITS and private funds such as hedge funds and private equity funds. For more information, visit http://www.sifma.org/amg.

2 Proposed Changes to the SASB Asset Management & Custody Activities Standard. Invitation to Comment on Exposure Draft and Basis for Conclusions (March 2021), available at https://www.sasb.org/standards/process/activeprojects/systemic-risk-in-asset-management/#.

3 Exposure Draft at 42.