SEC ESG Disclosures File Number S7-17-22,
Dear Ms. Countryman:
I’m writing to express my concerns about the lack of accessible and standardized information on how funds and investment advisers use environmental, social, and governance (ESG) factors. This means I don’t have the necessary information to make informed decisions about where I want to invest my hard-fought retirement savings.
When I am looking at funds to decide where to invest my retirement savings, I want to be able to feel confident that the names of funds are not misleading, and that the claims they make about how they take into account the environment, workers, and communities are backed up by detailed disclosures. I shouldn’t have to worry about putting my money in funds that don’t walk the walk. Those who manage my money should honor my choices and goals, not use misleading or unfounded claims to make higher fees and attract more investors.
Please consider incorporating the following in the final SEC Enhanced Disclosures by Certain Investment Advisers and Investment Companies about Environmental, Social, and Governance (ESG) (File No: S7-17-22) to protect working people who are currently saving or plan to save for retirement:
1. Only allow funds for which ESG factors are a significant or main consideration to use ESG language in their names; 2. Require engagement and proxy voting disclosures for certain funds; 3. Require GHG emissions disclosure for certain funds; and 4. Consider requiring or allowing disclosure of additional metrics that funds use to implement their ESG strategy. Sincerely,