[33044]
January 14, 2021 TO: ESG Advisory GroupESG Task Force
ICI Global Regulated Funds Committee
SEC Rules Committee RE: Draft ICI Letter on TCFD Forward-Looking Financial Sector Metrics Consultation
Attached for your review is a draft response to the Task Force on Climate-related Financial Disclosures (TCFD) Forward-looking Financial Sector Metrics Consultation.[1] Please provide any comments on the draft letter to Annette Capretta (acapretta@ici.org) by 12:00 pm ET, January 21. If you would like to discuss your comments, please email Annette to schedule a call. The consultation period ends on January 27, 2021.
The TCFD asks questions through an online survey. Attached is a PDF of the survey questionnaire, which we have been given permission to share with ICI members. Please do not forward this document outside of your organization.
ICI’s draft letter:
- Expresses support for TCFD’s work;
- Asserts that the challenges associated with company reporting of climate-related financial information needs to be addressed before considering the usefulness of reporting by asset owners or managers;
- Asks TCFD to lead efforts to address those challenges and offers ICI’s assistance; and
- Recommends that TCFD continue to pursue principles-based approaches, rather than overly-prescriptive ones.
Annette Capretta
Associate General Counsel
endnotes
[1] For a summary of the consultation, please see Memorandum No. 32979 (Dec. 14, 2020), available at https://www.ici.org/my_ici/memorandum/memo32979.