Memo #
33728

ICI Responds to IOSCO Consultation on Recommendations on Sustainability Related Practices, Policies, Procedures, and Disclosure in Asset Management
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[33728]

August 13, 2021

TO: ICI Members
ICI Global Members
ESG Advisory Group
ESG Task Force SUBJECTS: ESG
International/Global RE: ICI Responds to IOSCO Consultation on Recommendations on Sustainability Related Practices, Policies, Procedures, and Disclosure in Asset Management

Attached for your reference is our response to IOSCO's Recommendations on Sustainability Related Practices, Policies, Procedures, and Disclosure in Asset Management.[1]

Some highlights:

  • In general, we support the high-level recommendations proposed in the consultation paper and appreciate IOSCO's efforts to coordinate regulatory efforts across its member jurisdictions.
  • Proper sequencing is critical to fulfilling regulatory objectives. IOSCO should encourage its members to first address regulatory obligations for companies to provide sustainability-related information, which should yield more comparable, consistent, and reliable information for investors.
  • IOSCO should encourage its members to take a principles-based approach to any regulation related to sustainable finance, which is a rapidly evolving space and one where regulation should be flexible enough to permit asset managers to continue to innovate to meet the evolving objectives of their investors.
  • We caution against imposing minimum standards that attempt to create "categories" of products for investors rather than providing transparency for investors to make an informed investment choice.

Thank you to everyone who provided input on ICI's response. If you filed your own response, we would appreciate if you could share it with us to help us with further work on asset manager and fund disclosure.

Elizabeth Lance
Assistant Chief Counsel
ICI Global
 

endnotes

[1] The IOSCO consultation paper is available at https://www.iosco.org/library/pubdocs/pdf/IOSCOPD679.pdf. See also ICI Memo 33690 (16 July 2021) available at https://www.ici.org/memo33690.

    Attachments

    33728a.pdf

    Tags

    ESG
    Global ESG