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White Paper Submitted to the SEC Asset Management Advisory Committee’s ESG Subcommittee

August 19, 2020

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Ms. Vanessa Countryman
Federal Advisory Committee Management Officer
U.S. Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549-1090


Re: Asset Management Advisory Committee – File No. 265-33

Dear Ms. Countryman:

The Investment Adviser Association[1] (IAA) submits the attached white paper on sustainable investing to the Asset Management Advisory Committee’s ESG Subcommittee. The white paper, titled “Sustainable Investing is an Active Process,” was prepared by the IAA’s Active Managers Council. The Active Managers Council fosters education and thought leadership regarding active management, curates and sponsors research on active and passive management, and engages on relevant public policy issues. The IAA and the Active Managers Council are happy to serve as a resource to the Asset Management Advisory Committee as it continues to study ESG investing and other matters touching on active and passive management. Please feel free to contact us if we can be of any assistance.

* * *

Respectfully Submitted,
Karen L. Barr
President & CEO

[1]The IAA is the largest organization dedicated to advancing the interests of SEC-registered investment advisers. For more than 80 years, the IAA has been advocating for advisers before Congress and U.S. and global regulators, promoting best practices and providing education and resources to empower advisers to effectively serve their clients, the capital markets, and the U.S. economy. The IAA’s member firms manage more than $25 trillion in assets for a wide variety of individual and institutional clients, including pension plans, trusts, mutual funds, private funds, endowments, foundations, and corporations. For more information please visit

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