Jun. 17, 2022
Dear SEC, It is simply not possible to allow an investment fund or advisor to claim "ESG" status for any investment fund or investment strategy if they are selling securities to the public that contain material hidden costs or if they are buying securities on behalf of their clients and failing to disclose material hidden costs. As the SEC has known for two years, income-producing securities contain material and undisclosed hidden costs resulting from a backward accounting practice that treats liabilities as assets. This insane accounting practice artificially inflates the values (and fees) of income-producing securities. It also causes taxable investors to incur material losses because they will be subject to paying taxes on income they never earned. How can an investment manager claim to have "good governance" and then sell inflated securities to the public that have hidden costs which can be 10X higher than the management fee? If an investment advisor or fund wants to sell products to the public that have substantial hidden costs, then those costs MUST be disclosed to investors, in exact or nearly exact amounts, before the investor commits capital. On behalf of tens of millions of Americans who buy these products as a way to save for their well-being in retirement, I call on the SEC to enforce our disclosure laws that have been in existence since the 1930s and to prohibit any "ESG" fund from using "ESG" status unless it makes real-time disclosure of ALL material costs and risks to each potential investors before they commit capital. Thank you, Jeremy Roseberry CEO - FairShares, Inc.