Letters to Regulators: Environmental, Social, and Governance (ESG) Names and Disclosures for Investment Funds

Americans for Financial Reform Education Fund (AFREF) submitted comments to the Securities and Exchange Commission (SEC) on their proposed rules regarding fund names and required Environmental, Social, and Governance (ESG) disclosures for investment funds and advisers. These proposed rules would prevent the use of misleading fund names and require investment funds with sustainability-themed names like “ESG”, “Green” or “Socially Responsible” to disclose their investment strategy, shareholder engagement, and progress towards achieving their stated ESG-related goals and impacts. Environmentally focused funds would additionally need to disclose their financed greenhouse gas (GHG) emissions. AFREF offered recommendations to strengthen the proposals.

AFREF submitted an individual technical comment, a coalition sign-on comment with 97 signatories, a petition signed by over 19,000 advocates, and joined a comment led by the Action Center on Race and the Economy.