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IAA Comments on SEC’s ESG Issuer Proposal

June 21, 2022

IAA VP of Communications & Marketing Janay Rickwalder.


Washington, DC (June 21, 2022) – The Investment Adviser Association (IAA) submitted a letter to the SEC commending its proposal to enhance and standardize information disclosure to investors and investment advisers regarding climate-related risks and financial metrics.

“The IAA is pleased to have the opportunity to weigh in on this thoughtful proposal,” said IAA President and CEO Karen Barr. “Our members want consistent, comparable, and reliable information to make informed investment and voting decisions on behalf of their clients.”

The IAA generally supports the SEC’s adoption of rules that require disclosure of climate-related governance, risks, targets, and goals. We offer several comments and recommendations that we believe would further the SEC’s objectives and improve the Proposal. The IAA recommends that any rules the SEC adopts:

  • Balance flexibility for registrants and standardization of disclosures
  • Eliminate certain proposed prescriptive board oversight requirements
  • Require Scope 1 and Scope 2 GHG emissions disclosures, but we believe it is premature at this point to require disclosure of Scope 3 GHG emissions
  • Replace the proposed quantitative threshold for climate-related metrics and impacts with a materiality standard
  • Clarify the standard for materiality to be used for climate-related disclosures

We also encourage the SEC to work with its global partners, where appropriate, to increase harmonization in this area and recommend that the SEC not implement its proposed ESG rules for investment advisers, investment companies, or investment funds until the proposal has been finalized.

“Provided on a timely basis, this information can enhance investment advisers’ understanding, management, and disclosure of risk,” continued Barr. “Many investment advisers look to climate-related factors as a risk mitigator, so enhancements in reporting, standardization of reporting, and transparency can help them incorporate relevant data into their valuation models.”

The IAA looks forward to providing further feedback and working with the SEC as it considers this important issue.

View full comment letter.


About the Investment Adviser Association

As the leading organization for fiduciary investment advisers, the IAA advances the interests of member firms by providing essential expertise, crucial connections, and powerful advocacy tailored to their needs. Together, the IAA’s members manage more than $35 trillion in assets for a wide variety of clients, including individuals, trusts, investment companies, private funds, pension plans, state and local governments, endowments, foundations, and corporations. For more information, visit or follow us on LinkedIn, Twitter, and YouTube.


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