October 2023 Sample Examination Letter – Boston – Marketing Rule and ESG
This is a sample SEC examination letter from October 2023 from the Boston office that includes questions on the Marketing Rule and ESG investing.
October 31, 2023
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Comments on Wyoming’s Proposed Regulation of ESG Investing
The IAA recommended that Wyoming clarify that its proposed ESG rule would not apply to SEC-registered investment advisers or their representatives, pursuant to the National Securities Markets Improvement Act of 1996 (NSMIA).
September 18, 2023
Comments on the European Commission’s Consultation on Duties Regarding Sustainability
The IAA raised concerns that requiring asset managers to consider a particular set of sustainability factors when making investment decisions may dilute fiduciary principles and may run counter to the European Commission’s goals of efficient allocation of capital and sustainable and inclusive growth.
January 22, 2018
SEC Adopts Amendments to the Investment Company Act Names Rule
The SEC has adopted amendments to the Investment Company Act Names Rule to address its concerns about fund names that are likely to mislead investors about a fund’s investments and risks.
September 21, 2023
This article highlights the challenges advisers face around the current state of ESG investing and regulation and the considerations of disclosure, data, and portfolio management issues.
August 30, 2023
Comments on SEC Proposal to Enhance ESG Disclosures for Investment Advisers and Funds
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.
August 16, 2022
ESG Regulatory Frameworks for Pension Systems: Developments and Risks Relating to ESG
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July 19, 2022
Comments on SEC Proposal to Enhance and Standardize Climate-Related Disclosures 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.
June 17, 2022