Recommendations Regarding Issuer Disclosure of Material ESG Matters:

• –  The AMAC recommends the SEC take steps to foster meaningful, consistent, and comparable disclosure of material environmental, social, and governance (ESG) matters by issuers.
• –  To foster meaningful, consistent, and comparable disclosure, the SEC should encourage issuers to adopt a framework for disclosing material ESG matters and to provide an explanation if no disclosure framework is adopted.
• –  In addition, the AMAC recommends the SEC initiate a study of third-party ESG disclosure frameworks for the disclosure of material ESG matters to assess whether the frameworks could play a more authoritative role in the future.Recommendations Regarding ESG Investment Product Disclosure:

– The SEC should suggest best practices to enhance ESG investment product disclosure, including alignment with the taxonomy developed by the Investment Company Institute (“ICI”) ESG Working Group,2 and clear description of each product’s strategy and investment priorities, including description of non-financial objectives such as environmental impact or adherence to religious requirements.

– The SEC should suggest best practices for investment products to describe each product’s planned approach to shared ownership activities in the Statement of Additional Information, and any notable recent ownership activities outside proxy voting in Form N- PX(the Annual Report of Proxy Voting Record of Registered Management Investment Company).