Memo #
33102

Videoconference with SEC Staff to Discuss Recent ESG Comments - March 1 at 2:00 pm (Eastern)

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[33102]

February 10, 2021 TO: Disclosure Working Group RE: Videoconference with SEC Staff to Discuss Recent ESG Comments - March 1 at 2:00 pm (Eastern)

 

Please note that the next meeting of the Disclosure Working Group will be held via Zoom videoconference on Monday, March 1 from 2:00–3:00 pm (Eastern Time). The meeting will feature staff from the Securities and Exchange Commission’s Division of Investment Management, who will discuss recent comments related to funds with Environmental, Social and Governance investment strategies. Specifically, we are pleased to have the following staff members join us:

  • Michael Spratt, Assistant Director, Disclosure Review and Accounting Office, Division of Investment Management, SEC
  • Parisa Haghshenas, Branch Chief, Chief Counsel’s Office, Division of Investment Management, SEC
  • Elena Stojic, Attorney, Disclosure Review and Accounting Office, Division of Investment Management, SEC

Please submit any questions that you would like them to address to us in advance of the meeting, as the staff will be more likely to answer questions if they have sufficient time to review them. Note that we already are planning to ask the following:

  • We understand that the staff has viewed use of the words, “Sustainability” or “Sustainable” in a fund name to be synonymous with ESG and therefore subject to the fund names rule 80% asset test. If correct, could you explain the reasoning for this view? Are there other terms (e.g., “Green”) to which the staff applies the names rule?
  • Does the staff expect funds that integrate ESG into their investment strategies to provide the same disclosure as that expected of funds that use inclusionary, exclusionary, or impact investment strategies? Is there any difference in the detail expected?

A calendar invite for the working group meeting will be circulated shortly. If you have any questions about the meeting, please contact Nadia Ishmael at (202) 326-5811 or at nadia.ishmael@ici.org.

We look forward to seeing you at the meeting!

 

Kenneth Fang
Associate General Counsel