Americans for Financial Reform Education Fund (AFREF) submitted two letters in response to the Federal Trade Commission (FTC)’s request for comment on updates to its ‘Green Guides’ for the Use of Environmental Marketing Claims. The Guides were last revised in 2012. 

AFREF joined a coalition comment led by the Sierra Club asking the FTC to bring the Green Guides into alignment with international standards addressing greenwashing. The letter recommends tightening the rules around the marketing of “carbon offsets” and usage of offsets to justify sustainability claims. 

AFREF also submitted a letter on protecting consumers from greenwashing with respect to marketing of financial services and investments. Since the last version of the Green Guides were released, there has been a meteoric rise of Environmental, Social, and Governance (ESG) investing. More guidance is needed to establish what constitutes fair and faithful marketing and disclosure around financial products and services. The FTC should consider adding additional terms to the Guides to ensure that marketers are not purporting to deliver nonexistent benefits of their funds and misleading investors in their decision making.