Agency FilingFinancial RegulationRegulatory Activities

Comments on Department of Labor Proposed Rule on Prudence and Loyalty in Selecting Plan Investments and Exercising Shareholder Rights

These comments support a Department of Labor proposed rule that clarifies that retirement plan fiduciaries should consider climate risk and other ESG factors whenever relevant to financial risk-return analysis for investment and proxy voting decisions. The comments additionally offer suggestions on potential improvements to the proposal for the Department's consideration.
Blog/News ArticleFinancial DisclosureFinancial Regulation

Mandating Disclosure of Climate-Related Financial Risk (Blog)

This blog outlines reasons for supporting the SEC’s plan to propose a rule requiring standardized climate risk disclosures and provides several recommendations for how the SEC should build its institutional knowledge as it designs and enforces a climate risk disclosure regime, drawing on a forthcoming paper in the N.Y.U. Journal…
Adaptation as Risk ManagementAgency FilingEnergy RegulationFederal Energy RegulationRisk Management

Supplemental Comments on FERC’s Technical Conference on Climate Change, Extreme Weather, and Electric System Reliability

These post-technical conference comments provide further recommendations on how FERC can support effective climate resilience planning throughout the energy system, supplementing an earlier set of pre-technical conference comments.
Agency FilingFinancial DisclosureFinancial Regulation

Comments to SEC on Climate Risk Disclosure (ICRRL, Policy Integrity, EDF, Professors)

These comments make recommendations on the establishment of mandatory climate risk disclosure requirements that produce comparable, specific, and decision-useful information for investors, in response to the SEC's request for public input on climate disclosures.