Sustainable Finance Lobbying Overview: The Teachers Insurance and Annuity Association of America (TIAA) appears to have had somewhat mixed engagement on sustainable finance policy, along with its asset management arm Nuveen.

Top-Line Messaging on Sustainable Finance Policy: TIAA has called for global action to tackle climate change, supporting efforts to keep global temperature rise to 1.5C, and has called for government regulation to address the risks climate change poses to the financial system.

Position on Regulated Corporate ESG Disclosure: TIAA generally appears to support regulated corporate ESG disclosure. In a 2020 consultation on the EU’s Renewed Sustainable Finance Strategy, Nuveen supported requiring companies to disclose ESG data in order to improve investor decision-making. In an interview with CNBC in 2021, Nuveen’s CEO Jose Minaya stated support for regulatory action to drive consistent disclosure standards. In a 2021 letter to the SEC, TIAA called for mandatory climate risk disclosure requirements informed by TCFD guidelines. However, TIAA took a mixed position toward the SEC’s proposed climate disclosure rules in 2022, advocating for increased ambition in Scope 3 disclosure requirements but opposing certain qualitative risk management and assessment disclosure requirements. In its 2022 Climate Report, TIAA outlined its commitment to engaging with policymakers globally to highlight the need for a “robust disclosure regime.”

Position on Taxonomies and ESG Standards/Labels/Benchmarks: TIAA has outlined mixed positions with regard to policies on a taxonomy and ESG standards. In comments on the European Commission’s consultation on the Renewed Sustainable Finance Strategy in 2020, Nuveen supported the EU’s taxonomy to provide clarity for issuers but cautioned that stringent requirements might deter companies from making incremental progress. In those same comments Nuveen suggested that creating an ESG benchmark would be ineffective and “would require the EU to ‘pick a winner’ among ESG research and ratings providers” which would be “inappropriate.” In a 2020 consultation, Nuveen advocated for additional flexibility in the Technical Expert Group’s proposed EU Green Bond Standard, cautioning that inflexible requirements would limit issuance. In 2022, TIAA opposed the SEC’s proposed extension of the Names Rule to ESG-branded funds, stating a preference for enhancing disclosures for these kinds of funds to combat greenwashing. In its comments on the SEC’s accompanying “Enhanced Disclosures” rule, TIAA did not support the proposed ‘Integration Funds’ category, writing that it was “overly broad.”

Position on Incorporating ESG Factors Into Investor Duties: TIAA has taken a mixed position on incorporating ESG factors into investor duties. In 2020, TIAA opposed Department of Labor rules that sought to limit ESG investing and rollback shareholder rights, and opposed an SEC proposed rule that limited shareholder rights. In 2021, TIAA supported a Department of Labor proposal that reversed the 2020 rules limiting ESG investing, but took a more cautious approach when commenting on additional steps the Department could take to protect pensions and life savings from climate-related financial risk. Additionally, in 2022, TIAA outlined several concerns with the SEC’s proposed ESG disclosure rule for investors, not supporting quantitative disclosure requirements around proxy voting and engagement and portfolio Scope 3 emissions.

Position on Incorporating ESG Factors Into Risk Management/Prudential Regulation: In a 2021 response to the New York Department of Financial Services proposed guidance for insurers on managing financial risks from climate change, TIAA supported the need for regulations that incorporate climate change into risk management.

Industry Association Governance: Nuveen has disclosed some of its industry association memberships but with little detail of the sustainable finance policy positions of these groups.