SBAI Response - SEC ESG Rule - Aug 2022
- We are supportive of the SEC's distinction between ESG Integration, ESG Focused and ESG Impact strategies and believe this level of disclosure is important for investors to make informed investment decisions,
- We support the SEC's focus on process disclosure but note the following:
- Give the variety of ESG strategies any enacted rule needs to be flexible enough for asset managers to be able to accurately describe their strategy,
- Disclosures should only be required where asset managers market their ESG credentials in any way and not from firms that make no ESG claims, and
- The Brochure should contain all ESG information in one place rather than separate sections as described.
- We recommend that SEC specifically include engagement in their non-exhaustive list of methodologies but that it is acknowledged that not all alternative investment strategies will be able to use this as a tool in their ESG strategies.
Note that our response includes only the sections relevant to private fund advisers and not the sections applicable for funds targeted at retail investors.