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Comments on DOL ESG and Proxy Proposal

We support the DOL’s proposal related to ESG investing and proxy voting and recommend that the DOL remove certain ESG-specific language in the rule text and remove the proposed “collateral benefit” disclosure.

December 13, 2021

Tags: ERISA, ESG, Proxy Voting

Public Input on Climate Change Disclosures

The IAA weighed in on the ESG corporate disclosure debate with a letter to the SEC stressing the importance of facilitating sustainable investing by advisers on behalf of their clients and calling for consistent, comparable, and reliable baseline corporate issuer disclosures of climate- and ESG-related risks.

June 11, 2021

Tags: Climate, Disclosure, ESG, SEC

Response to European Commission’s Consultation on the Alternative Investment Fund Managers Directive

We responded to an EC consultation on the Alternative Investment Fund Managers Directive (AIFMD) to address issues relating to delegation and ESG. We urged the EC to preserve the well-regulated AIFMD delegation framework and that asset managers should not be required to integrate the assessment of adverse impacts on sustainability factors that are not sustainability risks into the investment decision making process.

January 28, 2021

Tags: Alternative Investment Funds, ESG, European Commission

Response to Consultation Paper on the Development of the CFA Institute ESG Disclosure Standards for Investment Products

We responded to a CFA Institute consultation on ESG Disclosure Standards for Investment Products. We urged CFA Institute to wait until regulators completed their deliberations and then determine whether there is a need for ESG product disclosure standards. Our responses focused on the need for and scope of the standards, our objection to the independent examination requirement, and ESG Integration and Proxy Voting, Engagement, and Stewardship as ESG-Related Features.

October 19, 2020

Tags: CFA Institute, ESG

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