March 6, 2024
Contact: IAA VP of Communications & Marketing Janay Rickwalder.
From Gail Bernstein, IAA General Counsel:
The Investment Adviser Association supports disclosures by public companies that are decision useful for investment advisers in making investment decisions on behalf of their clients. Disclosure of material climate-related governance, risk, targets, and goals, provided on a timely basis, can enhance investment advisers’ understanding, management, and disclosure of risk. The IAA thus commends the SEC for finalizing its proposal to strengthen and standardize information disclosure regarding climate-related risks and financial metrics.
We appreciate the SEC’s decision to prioritize climate-related disclosure rules for public companies before those focused on ESG factors for investment advisers and funds. This sequential approach will allow investment advisers and funds to have access to climate information from companies that will be necessary to inform related ESG disclosure requirements on them.
The IAA believes that not requiring Scope 3 GHG emissions disclosure is the right approach at this time. Current data limitations and the lack of standardized measurement methods make it premature to require such disclosures.
The IAA looks forward to providing further feedback and working with the Commission as it considers disclosures for advisers and funds.
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