Sustainable Finance Lobbying Overview: The Bank of New York Mellon (BNY Mellon) and its subsidiaries Insight Investment and Newton Investment Management have been engaged with sustainable finance policies in the US, EU, and UK, generally stating top-line support for sustainable finance policies while taking more mixed positions on specific regulations.

Top-Line Messaging on Sustainable Finance Policy: BNY Mellon has recognized the issue of short-termism in the financial sector but has stated that it is an “open question” as to whether financial markets can be restructured to address this issue. BNY Mellon has stated support for urgent action to tackle climate change, and subsidiaries Insight Investment and Newton Investment Management have signed on to the Net Zero Asset Managers Initiative, which advocates for net-zero by 2050 targets globally. BNY Mellon has stated broad support for sustainable finance regulation, “welcoming” sustainable finance initiatives in the EU and UK.

Position on Regulated Corporate ESG Disclosure: BNY Mellon has taken a mixed position on regulated corporate ESG disclosure, broadly supporting the need for disclosure but outlining objections to specifics of some policies. In its 2021 Climate Report, BNY Mellon welcomed efforts by governments to introduce formal climate disclosure requirements for companies. Insight Investment and Newton Investment Management signed on to the 2022 Global Investor Statement to Governments on the Climate Crisis, calling on policymakers to mandate TCFD-aligned reporting and require disclosure of 1.5C pathway-aligned transition plans. In 2022, head of Responsible Investment for Insight Investment welcomed the US Securities and Exchange Commission’s (SEC) efforts to require corporate climate disclosures. In September 2022, BNY Mellon, as constituents of the Financial Services Forum, met with the SEC to discuss concerns about the Commission’s proposed climate disclosure rule, including “burden and cost.” In comments on the UK Green Finance Strategy update in 2022, Insight Investment supported efforts to enhance regulated climate disclosures, but asserted that Scope 3 emissions disclosure should only be mandated after consistent methodologies and standards have been developed.

Position on Taxonomies and ESG Standards/Labels/Benchmarks: BNY Mellon has expressed positive positions toward a EU taxonomy on its website, but in 2021, Insight Investment’s head of responsible investment research told FTAdviser that the EU’s version of a green taxonomy was overly complicated and should be more “flexible.”

BNY Mellon has expressed support for policy on ESG labels. In 2021 Insight Investment stated support for the UK’s new green gilt framework, and in 2022 welcomed the FCA’s proposed sustainable product labels.

Position on Incorporating ESG Factors Into Investor Duties: BNY Mellon has taken mixed positions on policies to incorporate ESG factors into investor duties.. In 2020, BNY Mellon did not support a Trump Administration-era Department of Labor rule that sought to limit ESG investing, and strongly supported the 2021 reversal of this rule, advocating for further clarity around the ability to use ESG factors in decision-making. However, in comments to the Department of Labor in May 2022, Insight did not support requiring retirement plans to disclose climate-related data, and in comments to the UK Department for Work and Pensions in January 2022, Insight suggested it was “premature” to require trustees to report on the Paris-alignment of their pension schemes.

Position on Incorporating ESG Factors Into Risk Management/Prudential Regulation: The 2022 Global Investor Statement, signed by Insight and Newton, calls for increased ambition in incorporating ESG factors into prudential risk supervision. A memo from the SEC shows that BNY Mellon, as constituents of the Bank Policy Institute, met with the Office of the Comptroller of the Currency to discuss “challenges” with the Office’s draft principles for climate-related financial risk management.

Industry Association Governance: BNY Mellon and its subsidiaries have disclosed memberships to industry associations, and have listed some details of engagement with these associations on sustainable finance policy across reports, but without a full assessment of the sustainable finance policy positions of these organizations or any action taken to address misalignment.