SIFMA Response: ESMA Consultation on ESG Ratings Providers:
6.2 Questionnaire B for Users of ESG Rating Providers:
[LL Note: the actual submission was made using an online form. Contribution ID: 9bc994c2-8109-4e4b-a61b-caabadfce1cd]
Q1: Name of respondent or organisation (including Legal Entity Identifier).
The Asset Management Group of the Securities Industry and Financial Markets Association (“SIFMA AMG”) is making this submission on behalf of its members.
Q2: Nature of establishment in EU
(A) Legal entity established in EU
▪Please indicate Member State(s) of legal entities
(B) Legal entity and corporate headquarters established in EU
▪ Please indicate country of corporate headquarters
(C) No legal entity or corporate headquarters established in EU
▪ Please indicate country of corporate headquarters
(D) Other
▪ Please explain
(D): SIFMA AMG is a US based trade association that represents the asset management community, provides views on U.S., European and global policy and seeks 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.
Our members are active participants in the sustainability journey and have first-hand experience of utilising ESG ratings products and data providers. SIFMA AMG welcomes the opportunity to provide feedback on ESMA’s Consultation on ESG Ratings Providers.
Q3: Respondent subject to any existing financial regulatory authorisation, registration or supervisory regime.
(A) Yes
▪ Please provide further details of regime including name of authorisation, registration, or supervisory body and reference to supporting legal acts.
Although SIFMA AMG itself isn’t regulated, our members include a variety of regulated firms, that have an authorised presence in leading financial jurisdictions such as the US, EU and the UK (among others).
(B) No