Climate Finance Policy Engagement Analysis
Climate Lobbying Overview: The American Retirement Association (ARA) appears to have had limited engagement with climate-related finance policy but, where it has engaged, ARA has been generally supportive of efforts to permit the use of climate factors in investment decision making.
Top-Line Messaging on Climate-Related Finance Policy: In a 2021 letter to the SEC the ARA stated its preference for sustainable finance policy action by a government entity rather than an industry-led body.
Position on Regulated Corporate Climate Disclosure: In a 2021 response to the SEC’s request for public input on climate change disclosures, the ARA voiced support for a regulated climate disclosure framework, pointing to the growing use of climate factors in retirement investing.
Position on Incorporating Climate Factors Into Investor Duties: In 2021 comments on the Biden administration’s proposed rollbacks of the Trump-era Department of Labor rules that restricted ESG investing, the 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. In an 2021 press release CEO Brian Graff initially expressed support for the 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.” In May 2022 comments to the Department of Labor, the ARA did not support regulatory action to require fiduciaries to consider climate risk in decision making. However, the ARA has pushed back on “anti-ESG” efforts to limit ESG investing, in a 2022 press release opposing a bill that sought to overturn the Biden-era Department of Labor’s ESG rule. In March 2023, when this bill passed, CEO Brian Graff applauded Biden’s use of the veto to stop the measure. In April 2024, ARA filed an amicus brief in support of the Department’s rule.