We have expanded the list of climate policies we assess company engagement with to incorporate land-use related policy, referring to legislative or regulatory measures to enhance and protect ecosystems and land where carbon is being stored. Assessments under this category are currently underweighted in terms of their contribution to the overall company metrics. This weighting will be progressively increased over the next 6 months.
We adjusted the terminology used to describe the queries running down the left-hand side of our scoring matrix and added additional explanatory text to the info-boxes. This has no impact on the scores and methodology. It has been done following user feedback to improve clarity.
The American Retirement Association (ARA) appears to have had limited engagement with sustainable finance policy but, where it has engaged, ARA has been generally positive.
In a 2021 response to the SEC’s request for public input on climate change disclosures, ARA voiced support for a regulated climate disclosure framework, pointing to the growing use of ESG factors in retirement investing. In the same comments, ARA voiced its preference for sustainable finance action by a government entity rather than by an industry-led entity.
ARA appears to be broadly supportive of policies that would incorporate ESG factors into investor duties. In 2020 the Association opposed the Trump-era Department of Labor rules that sought to limit ESG investing and shareholder rights, and in 2021 ARA wrote a letter to Labor Secretary Walsh expressing its strong belief that ESG factors be considered material. Additionally, ARA has expressed support for legislation that would provide legal certainty for workplace retirement plans that choose to consider ESG factors in their investment decisions. However, in 2021 comments on the Biden administration’s proposed rollbacks of the Trump-era Department of Labor rules, ARA asked the Department to remove references to ESG considerations in rule language and voiced concern about an implied requirement to consider ESG factors in investment decision making. CEO Brian Graff initially expressed support for the Labor Department’s proposal, but in a March 2022 interview Graff expressed concern that requirements on evaluating climate risk would become “too prescriptive” and warned against “overemphasizing climate change.”
ARA’s separate policy advocacy website lists the comment letters and statements to Congress it has submitted, including those related to sustainable finance policies, but ARA has not disclosed information on other engagement activities. ARA lists its board membership but does not disclose general membership.