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.