220812 Comments CCMC ESG Disclosures SEC 1


August 12, 2022


The U.S. Chamber of Commerce’s (“the Chamber”) Center for Capital Markets Competitiveness (“CCMC”) submits these comments in response to the proposed rule from the Securities and Exchange Commission (“Commission”) entitled “Environmental, Social, and Governance Disclosures for Investment Advisers and Investment Companies” (“Proposal”). The Proposal would mandate extensive new requirements for funds and investment advisers regarding their use of environmental, social, and governance (“ESG”) factors when developing investment strategies.

The Proposal states that “investors looking to participate in ESG investing face a lack of consistent, comparable and reliable information among investment products and advisers that claim to consider one or more ESG factors.” The Proposal further notes that a lack of standardized ESG disclosures “creates the risk that funds and advisers marketing [ESG] strategies may exaggerate their ESG practices or the extent to which their investment products or services take into account ESG factors.” This concern over “greenwashing” is cited as justification for new rules throughout the Proposal.

220812 Comments CCMC ESG Disclosures SEC 1