SBAI Comments on FCA CP on Short Selling

The SBAI expands on existing frameworks for GHG-emission accounting to develop a methodology that allows for the incorporation of derivatives and short positions. The framework outlines the case for inclusion from the perspective of measurement of GHG-emission risk exposure and sustainability outcomes (impact).

The Securities and Exchange Commission (SEC) has introduced new rules to address conflicts of interest when advisers offer investors the choice between selling or exchanging their interests in a private fund for interests in another vehicle managed by the adviser or related parties. In this piece, we explore the impacts of these new rules for investors and managers and highlight considerations for effective implementation.

In our response, we highlight key positions we view as important when developing rules in the area of Safeguarding Advisory Client Assets.