Morningstar Comment to DOL/EBSA on ESG

Morningstar’s comment to DOL/EBSA urges the Department to require consideration of ESG factors in pension investments, not discourage it. Simply stated, the Labor Department’s proposed rule is out of step with the best practices that asset managers and financial advisors use to integrate ESG considerations into their investment processes and selections. Indeed, as we outlined in…

Teamsters Comment on DOL/EBSA ESG Proposal

The Teamsters comment on the DOL/EBSA is attached in full below. An excerpt: The Proposal offers a solution in search of a problem. For almost 30 years ESBA has issued a series of bulletins providing guidance to fiduciaries regarding their obligations when it comes to selecting investment options for plan participants. That guidance has emphasized…

Minerva Comment Letter on DOL/EBSA ESG Proposal

From the comment filed by Minerva Analytics on the DOL/EBSA ESG proposal (full text attached below): The Proposed Rules stand in stark contrast to many OECD markets and appear to contradict decades of guidance from the DoL which has allowed ERISA-regulated retirement plans to invest responsibly and take ESG factors into account, under appropriately strict…

CII Comment on Proposed DOL ESG Rule

CII’s comment to DOL/EBSA includes an outstanding list of empirical studies supporting the financial impact of ESG factors. The full comment is below. An excerpt: We also believe the Proposed Rule would create significant burdens of proof for investment approaches that emphasize investment risk and opportunities around ill-defined ESG matters, without subjecting funds that dismiss…

ISS Comment on DOL/EBSA ESG Proposal

ISS has filed a comment with DOL/EBSA on the ESG proposal. An excerpt, and the full text below: While the Department seems to recognize the economic relevance of ESG factors in theory, the Proposing Release nonetheless perpetuates outdated assumptions about ESG investing. As a result, the proposed amendment of Rule 404a-1 imposes unnecessary burdens on…

SASB Comment on DOL/EBSA ESG Rule

SASB’s comment emphasizes the financial impact of ESG disclosures. An excerpt, with the full comment below: Why, given the evidence of financial materiality found by SASB and numerous scholars, would ESG investing be singled out by DOL for a special rule, a special documentation requirement, and a “heightened” level of scrutiny? The DOL’s pejorative treatment…

Our Comment to DOL/EBSA on ESG

July 20, 2020 Assistant Secretary Preston Rutledge EBSA Department of Labor 200 Constitution Ave, NW, Ste S-2524 Washington DC 20210 RE: RIN 1210-AB95 NPRM: Financial Factors in Selecting Plan Investment Dear Assistant Secretary Rutledge, We have the strongest possible objections to the proposed rule on the appropriate consideration of ESG or any other non-traditional factors…

Jon Lukomnik Comment Letter to DOL/EBSA on ESG Rulemaking

Jon Lukomnik’s letter to DOL/EBSA about the proposed rule on ESG investing has been co-signed by distinguished academics and investment professionals, along with VEA’s Chair, Vice Chair, and President. Attention: Financial Factors in Selecting Plan Investment Proposed Regulation. To Whom It May Concern: We are writing in opposition to proposed rule RIN 1210-AB95. We believe…

DOL Quietly Joins SEC’s Shareholder Voter Suppression Effort

Here is the latest from the DOL in intentionally bureaucratic gobbledygook: This deregulatory action would modernize fiduciary practices related to the voting rights associated with ERISA plan investments and harmonize those regulations with the requirements of other regulators. The goal of this proposal would be to protect the interests of participants and beneficiaries by: (1)…