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The IAA strongly supports the view that investment advisers and funds should clearly articulate their investment strategies, including ESG strategies, so that investors understand the investment adviser’s philosophy and can make informed investment decisions. While we are generally supportive of the SEC’s proposal to move forward with specific ESG disclosure requirements, we have concerns about its broad scope, which we believe could obscure rather than clarify salient information for investors.
We generally support the SEC’s proposal to require disclosure of material information about climate-related financial risks and climate-related financial metrics and provide recommendations that we believe will further the SEC’s objectives. Having consistent, comparable, and reliable disclosures of material information from public issuers, including disclosures related to climate-related matters, would help investment advisers make informed decisions on behalf of their clients.
The IAA weighed in on the ESG corporate disclosure debate with a letter to the SEC stressing the importance of facilitating sustainable investing by advisers on behalf of their clients and calling for consistent, comparable, and reliable baseline corporate issuer disclosures of climate- and ESG-related risks.
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