Subject: S7-17-22: WebForm Comments from Jeffrey Vincent
From: Jeffrey Vincent
Affiliation: Retired Defence/ Aerospace Executive

Jul. 13, 2022

July 13, 2022

 To be fair, I am not an ESG investor. Research has shown that investor returns are lower when investing in ESG funds. I believe that blended funds should not be required to provide the ESG information if there ESG investments in a blended fund is less than 50% of total fund assets.

I would also point out that the SEC does not really have a charter from Congress on ESG investing and should therefore not be involved in this type of regulation. The recent Supreme Court ruling on The West Virginia energy case indicates that agencies like SEC do not have this authority.