Managed Funds Association

Sector

Asset Management

Headquarters

Washington D.C., United States

Climate Finance Policy Engagement Analysis

Climate Lobbying Overview: The Managed Funds Association (MFA) appears unsupportive of stringent regulatory intervention on climate finance. MFA does not appear to be engaged on real economy climate policy.

Top-Line Messaging on Climate-related Finance Policy: In a 2022 research paper, MFA stated support for addressing climate change but did not provide a clear level of ambition.

Position on Regulated Corporate ESG Disclosure: MFA appears generally unsupportive of regulated corporate ESG disclosure. In comments to the UK Financial Conduct Authority (FCA) in 2021, MFA advocated for reporting requirements for asset managers to be delayed by a year, and in comments to the US Securities and Exchange Commission (SEC) in 2022, MFA asserted that investments should be excluded from reporting requirements. In comments to the International Sustainability Standards Board (ISSB) in 2022, MFA opposed mandatory disclosure of Scope 3 emissions.

Position on Climate/ESG Standards, Labels and Benchmarks: In comments to the US SEC in 2022, MFA supported the need to introduce categories for ESG-related funds, but advocated for narrower definitions, particularly for "ESG Integration" funds. In its 2023 response to the FCA’s consultation on investment labels, MFA argued for a more flexible approach to ESG labels and a delay to implementation.

Position on Incorporating ESG Factors Into Investor Duties: MFA has been unsupportive of policies to incorporate ESG factors into investor duties. In 2023 comments to the European Supervisory Authorities (ESAs) on their review of SFDR delegated regulation MFA urged the authorities to “pause this work to avoid the unintended negative consequences of investor and market confusion and of diversion of valuable investor resources.”

In comments to the SEC in 2022 MFA outlined concerns with proposed disclosure requirements for ESG investors, advocating for narrower criteria, and in follow-up comments in 2023 MFA suggested the costs of this rulemaking would outweigh its benefits.

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InfluenceMap Score for Climate Finance Policy Engagement

D-

Performance Band

41%

Organization Score

9%

Engagement Intensity

Primary Evidence

All primary evidence used to inform the analysis of Managed Funds Association can be found in the two tabs below below. In the first tab, hyperlinks in each cell of the matrix provide access to evidence collected on Managed Funds Association's direct policy engagement activities. The second tab provides a record of any links between Managed Funds Association and the Industry Associations stored in the LobbyMap database.

DATA SOURCES
QUERIES
Main Web Site

Main Web Site

Corporate Media

Corporate Media

CDP Responses

CDP Responses

Direct Consultation with Governments

Direct Consultation with Governments

Media Reports

Media Reports

CEO Messaging

CEO Messaging

Financial Disclosures

Financial Disclosures

Reforming the financial sector: Does the organization support the need for systemic reforms to deliver a sustainable financial system?

NSNSNA0NSNSNA

Climate Science Stance: Does the organization support a science-based response to the climate crisis?

0NSNA0NSNSNA

Need for climate policy: Does the organization support the need for climate-related finance regulation?

-1NSNA-1NSNSNA

Disclosures: Does the organization support regulated corporate climate disclosure?

NSNSNA0NSNSNA

Taxonomies: Does the organization support a taxonomy?

NSNSNA0NSNSNA

Financial Products and Ratings: Does the organization support climate standards, labels and/or benchmarks for financial products and policy on ESG ratings?

NSNSNA0NSNSNA

Investor Duties: Does the organization support policy to incorporate climate factors into investor duties?

NSNSNA-1-1-1NA

Prudential Regulation: Does the organization support policy to incorporate climate factors into risk management/ prudential regulation?

NSNSNA-1NSNSNA

Real Economy Climate Regulations: the organization support real economy climate policy and regulation?

NSNSNANSNSNSNA

Energy, Industry and Land Transitions: Does the company support energy, industry and land transitions as required by the IPCC?

NSNSNANSNSNSNA

Disclosure on Lobbying: Is the organization being transparent about their positions on climate legislation and policy?

2NSNANSNSNSNS

Disclosure on Relationships: Are companies being transparent about their business associations which may impact climate debate and policy?

2NSNANSNSNSNS