Sustainable Finance Lobbying Overview: JPMorgan Chase & Co. (JPMorgan) appears to have had limited engagement on sustainable finance policy, but, where it has engaged, appears not to have supported stringent regulatory intervention despite some top-line statements of support. A significant amount of JPMorgan’s position-taking emerges via its asset management arm, JPMorgan Asset Management.

Top-Line Messaging on Sustainable Finance Policy: JPMorgan has stated support for the goals of the Paris Agreement and efforts to limit temperature rise to 1.5C. In 2021 JPMorgan joined the Net Zero Banking Alliance and JPMorgan Asset Management joined the Net Zero Asset Managers initiative, supporting the goal of net zero by 2050. However, JPMorgan appears to support a less stringent climate response than the IPCC, supporting continued investment in oil and gas. In October 2021, JPMorgan’s head of ESG for EMEA suggested that oil and gas companies were “part of the solution” to climate change. CEO Jamie Dimon has stated support for accelerating the transition to a low carbon economy but has also advocated for a continued role for oil and gas. In his letter to shareholders in 2022, Dimon argued that for the purposes of energy security the US must increase oil and gas production, asserting that this increased production would not conflict with long-term climate goals. Dimon also directly advocated for the Biden Administration to scale up investments in the US fossil fuel sector in the midst of the Russian invasion of Ukraine, and in a 2023 interview Dimon asserted that the world would need “cheap oil and gas for 50 years.” A letter submitted to the Municipal Advisory Council of Texas in September 2022 shows evidence of JPMorgan’s continued support for investing in fossil fuels. JPMorgan Asset Management has described engaging with regulators on sustainable finance policies and has stated support for “the healthy growth of ESG implementation.”

Position on Regulated Corporate ESG Disclosure: JPMorgan Asset Management has voiced some support for regulated corporate ESG disclosure, contrasting with JPMorgan CEO Jamie Dimon’s stated opposition to mandated climate reporting. Both JPMorgan and its asset management arm have outlined concerns with the US Securities and Exchange Commission’s (SEC) proposed climate disclosure rule.

In an interview with ESG Investor in 2021, Global Head of Sustainable Investing Jennifer Wu stated support for mandatory climate disclosures, and in an interview with ESG Clarity in August 2022, APAC Lead Sustainable Investing Strategist Tomomi Shimada stated support for mandatory corporate ESG disclosures in Asia. A 2021 paper on JPMorgan Asset Management’s website suggests support for moves toward regulated corporate ESG disclosure in China. However, in a Wall Street Journal article from October 2022 JPMorgan Asset Management appears unsupportive of the SEC mandating Scope 3 emissions disclosure, and a September 2022 memo shows that JPMorgan, as constituents of the Financial Services Forum, met with the SEC to discuss its proposed climate disclosure rule, including concerns about "burden and cost," time for implementation, and financial statement provisions. Finally, InfluenceMap obtained documents that show that JPMorgan raised concerns with the EU Corporate Sustainability Reporting Directive (CSRD) in a December 2022 meeting with the Executive Vice-President of the European Commission.

Position on Taxonomies and ESG Standards/Labels/Benchmarks: In a 2022 article, JPMorgan Asset Management appeared supportive of the EU taxonomy, stating that it would improve investor decision-making.

In comments to the SEC in 2022, JPMorgan Asset Management supported the introduction of three ESG-related fund categories, and supported extending the Commission’s “Names Rule” to funds with ESG-related terms in their names but requested that the Rule’s 80% investment compliance be tested less frequently than proposed. JPMorgan Asset Management also generally supported the UK Financial Conduct Authority’s (FCA) proposed ESG product labeling and standards in a January 2022 comment letter. In February 2023, Responsible Investor reported that JPMorgan Asset Management did not support the European Securities and Markets Authority’s (ESMA) proposed guidelines for funds with names that use ‘ESG’ or ‘sustainability.’

Position on Incorporating ESG Factors Into Investor Duties: In a 2022 paper JPMorgan Asset Management appeared to support the EU’s Sustainable Finance Disclosure Regulation (SFDR). In 2022 comments on the SEC’s proposed disclosure requirements for investment advisers and investment companies on ESG investment practices, JPMorgan Asset Management broadly supported the proposal but recommended a summary approach to disclosure rather than the detailed draft requirements, and recommended that funds not be required to disclose Scope 3 emissions.

Position on Incorporating ESG Factors Into Risk Management/Prudential Regulation: In a 2021 paper JPMorgan Asset Management appeared to support the European Commission’s proposal to apply climate stress scenarios to insurers’ balance sheets. A March 2022 memo from the Office of the Comptroller of the Currency (OCC) shows that JPMorgan, as constituents of the Bank Policy Institute, met with the OCC to outline “challenges” to its draft principles for climate-related financial risk management.

Industry Association Governance: JPMorgan Asset Management has detailed some of the sustainable finance policies it is tracking with some level of detail on desired outcome, but no detail on efforts to influence outcome. JPMorgan lacks such disclosure. JPMorgan has disclosed memberships to US trade associations but has not given details on the sustainable finance policy positions of these organizations. The disclosure is also missing Europe-based memberships such as EFAMA and PensionsEurope.