Jun. 15, 2022
The Association for Real Estate Funds (AREF) represents the UK real estate funds industry and has around 60 member funds with a collective net asset value of more than £64 billion under management on behalf of their investors. The Association is committed to promoting transparency in performance measurement and fund reporting through the AREF Code of Practice, the MSCI/AREF UK Quarterly Property Funds Index and the AREF Property Fund Vision Handbook.
AREF wholeheartedly supports the implementation of climate-related disclosures. This is something the real estate fund industry have been focussing on for a while as the real estate sector a significant carbon footprint. It is estimated that the sector currently contributes 30% of global annual greenhouse gas (GHG) emissions and consumes around 40% of the world's energy, according to the UN Environmental Programme.
We are pleased to see that the SEC have modelled the proposed disclosure rules in part on the TCFD disclosure framework. We agree that building on the TCFD framework will ensure there is familiarity and consistency globally both for the firms reporting under the rules and their investors who wish to compare climate-related disclosures across their investments.
We have responded to consultations on climate-related disclosures published by the Government and Financial Conduct Authority (FCA) in the UK and the European Supervisory Authorities (ESAs) in the European Union. Within all of these responses we have stressed the importance that the rules and regulations must include climate-related disclosures that are relevant for real estate.
On 13 April 2022 we submitted, with other real estate associations in the UK and Europe, a paper to the FCA on ESG metrics for real estate (please find the paper attached; the names of the associations that supported and contributed to the paper can be seen at the top of the document). The principles and real estate specific metrics mentioned within the paper aim to facilitate consistency of disclosures both across the EU and UK as well as internationally where the TCFD’s recommendations will apply. Also, we anticipate the reporting principles to dovetail with standards to be adopted by the International Sustainability Standards Board (ISSB). We have shared the paper with real estate related associations in US, Canada and Australia who have welcomed the aims of the paper. While we support consistent reporting and disclosure by international asset managers, we do appreciate that local supplements may be appropriate or needed for domestic real estate specific metrics.
We would ask that the requirements of investors in real estate funds are taken into consideration when finalising the SEC’s rules on climate-related disclosures.
Kind regards
Jacqui Bungay
Jacqui Bungay | AREF Policy Secretariat
T: 020 7269 4677 D: +44 20 7269 4648 M: +44 79 5092 6044
E:
This message, including any attachments, may contain confidential and privileged material; it is intended only for the person to whom it is addressed. If you are not the intended recipient, do not forward it or copy it or act upon its contents, but please report it to
No responsibility can be accepted by AREF for action taken which is the result of information contained in this correspondence. Recipients should take specific advice when dealing with specific situations.
AREF assumes no liability or responsibility for the consequences arising out of a delay and/or loss in transit of this message, or for corruption or other error(s) arising in its transmission and for any misuse or fraudulent use which may be made thereof. AREF has the right to record, monitor and inspect messages between its employees and any third party. Your messages shall be subject to such lawful supervision as necessary in order to protect its information, interests and reputation.
AREF prohibits and takes steps to prevent its information systems from being used to view, store or forward offensive or discriminatory material. If this message contains such material please report it to
Switchboard +44 (0) 20 7269 4677
The Association of Real Estate funds is a company limited by guarantee.
Registered Office: Camomile Court, 23 Camomile Street, London, EC3A 7LL
Registered Number: 04601584