Maura Hodge, Sam Jeffery, and Julie Santoro are partners at KPMG LLP. This post is based on their KPMG memorandum.
Related research from the Program on Corporate Governance includes The Illusory Promise of Stakeholder Governance (discussed on the Forum here) by Lucian A. Bebchuk and Roberto Tallarita; For Whom Corporate Leaders Bargain (discussed on the Forum here) and Stakeholder Capitalism in the Time of COVID (discussed on the Forum here), both by Lucian A. Bebchuk, Kobi Kastiel, and Roberto Tallarita; and Restoration: The Role Stakeholder Governance Must Play in Recreating a Fair and Sustainable American Economy—A Reply to Professor Rock (discussed on the Forum here) by Leo E. Strine, Jr.
About the proposal
- On March 21, 2022, the SEC issued proposed rule, The Enhancement and Standardization of Climate-Related Disclosures for Investors.
- The comment period closed on June 17. We have identified key themes from the responses.
- Regardless of this proposal, compliance with existing requirements includes the 2010 climate-related guidance issued by the SEC staff.
Get a recap
- This post assumes a working knowledge of the proposal.
- For a brief recap on the proposal, see our Defining Issues, SEC proposes climate reporting and assurance rules.
- To understand the proposal in more depth, see the Top 10 questions in our talk book, Understanding the SEC’s climate proposal.
Toward a final rule
- The SEC’s Spring 2022 regulatory agenda shows publication of a final rule in October 2022.
- Other ESG-related items on the regulatory agenda include proposals related to human capital management disclosures (October 2022) and corporate board diversity (April 2023); and finalization of ESG requirements for investment companies and investment advisers (see our Defining Issues on the proposals).
Enhanced ESG Disclosures for Investment Funds and Advisers: A Comment from BlackRock
More from: Elizabeth Kent, Paul Bodnar, BlackRock
Paul Bodnar is Global Head of Sustainable Investing and Elizabeth Kent is a Managing Director at BlackRock, Inc. This post is based on a comment letter by BlackRock submitted to the U.S. Securities and Exchange Commission regarding the proposed rules on ESG disclosures for investm ent funds and advisers.
This post is based on a comment letter submitted to the SEC regarding the proposed rules on ESG disclosures for investment funds and advisers by BlackRock. Below is the text of the letter with minor adjustments to eliminate the correspondence-related parts.
BlackRock, Inc. (together with its subsidiaries, “BlackRock”) respectfully submits the following response to the Securities and Exchange Commission’s (“SEC”) proposed rule “Enhanced Disclosures by Certain Investment Advisers and Investment Companies About Environmental, Social, and Governance Investment Practices” (“the proposal”). [1] We commend the SEC for taking this step to promote investors’ access to consistent, comparable, and reliable information about investment funds’ and investment advisers’ incorporation of environmental, social, and governance (“ESG”) criteria into their investment processes.
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