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 Managed Funds Association (MFA) has had limited engagement on sustainable finance policy but, where it has engaged, appears not to have supported stringent regulatory intervention on the issue.
MFA seems to have neither a clear position on either the need for financial sector reform nor financial sector action on climate. MFA appears to be skeptical of the need for sustainable finance regulation, preferring a market-based approach.
In a 2021 letter to the SEC, MFA voiced support for the need for policy to improve corporate climate risk disclosure.
In a letter to the European Commission in 2018, MFA expressed support for the taxonomy. However, in feedback to the European Commission in 2020, MFA opposed the expansion of the taxonomy to cover environmentally harmful activities.
In feedback to the European Commission in 2020, MFA argued against updating fiduciary duty to integrate ESG factors. In 2018/9, MFA argued for weaker policy on including ESG considerations in the advice investment firms give to clients in consultation responses to the European Commission and ESMA. In response to the ESA’s Sustainable Finance Disclosures Regulation (SFDR) consultation on investor ESG disclosure in 2020, MFA argued for a less prescriptive approach to investor ESG disclosure regulation, including a reduced number of mandatory indicators. In 2020, MFA supported the SEC's climate change disclosure rule with major exceptions, particularly around the reporting of invested emissions.
In 2020, MFA did not support US Department of Labor's rollback which limited fiduciaries' ESG investing, however, it supported certain aspects of the DOL's rollback on voting on ESG issues.