In September 12th letters to the U.S. Securities and Exchange Commission (SEC), the Business Roundtable, the Investment Company Institute, and the US Chamber of Commerce outlined their opposition to proposed rule amendments that seek to expand shareholder rights.
On September 8th, the Investment Company Institute President and CEO, Eric Pan, wrote an op-ed criticizing the Texas Comptroller’s decision to ban financial institutions from doing business with the state due to consideration of ESG factors in investment strategies, writing that the decision would “meddle in the financial security of hundreds of thousands of Texas public servants.” Pan also criticized the “heavy-handed actions” of blue states like California, which is “steadily moving toward forcing its public pension funds to divest from fossil fuels.” Pan asserted that financial markets must be “driven by market fundamentals and investor choice” rather than “government imposing its will.”
In July 29th responses to the International Sustainability Standards Board’s (ISSB) Climate and Sustainability Disclosure Exposure Drafts, several financial groups including abrdn, Capital Group, HSBC Bank Pension Scheme, Nordea Asset Management, and Northern Trust Asset Management expressed support for the ISSB's proposed Scope 3 emissions disclosure requirements.
In a tweet on 1st July, EDF supported the inclusion of fossil gas alongside nuclear in the EU Taxonomy complementary delegated act, stating that there are no economically viable alternatives.
In a tweet on 6th July, the Verband der Chemischen Industrie (VCI) supported the EU Parliament taxonomy vote and the temporary categorization of fossil gas as sustainable. Meanwhile, in a Euractiv article from the same day, the Federation of German Industries (BDI) was quoted as supporting the EU Parliament taxonomy vote, stating support for 'renewable and alternative gases' as bridge technologies in the energy transition.
In a 6th July press release, GasNaturally President Dawn Summers supported a weakening of the EU Sustainable Finance Taxonomy, by including a transitional role for fossil gas. Summers supported the EU Parliament’s decision not to veto the EU Sustainable Finance Taxonomy Delegated Act. Meanwhile, Eurogas Secretary-General James Watson welcomed the EU Parliament’s decision to include fossil gas in the EU Sustainable Finance Taxonomy, in a 6th July Euractiv article. Watson also called for more support for LNG imports.
In a June 17th letter to the US Securities and Exchange Commission (SEC), Business Roundtable supported the climate disclosure rule with several major exceptions, including not supporting requirements on Scope 3 emissions and describing that the SEC’s cost-benefit analysis was “fundamentally flawed”
In June 16th and 17th comment letters to the US Security and Exchange Commission (SEC), financial industry associations including the Reinsurance Association of America, the Bank Policy Institute, the American Bankers Association, the American Property Casualty Insurance Association, and the Securities Industry and Financial Markets Association outlined objections to the SEC's proposed climate disclosure rule. The groups characterized the proposal as insufficiently flexible and asked for several disclosure provisions to be removed or altered.
In a May 31st submission to the U.S. Securities and Exchange Commission (SEC), Keidanren (the Japanese Business Federation) opposed several key components of the SEC’s proposed climate change disclosure rule, including mandatory scope 3 reporting, the requirement to disclose the financial impacts of climate change, and the requirement to publish an attestation report. It also called for a delay to implementation of the rule.
On May 26th 2022, Bloomberg reported that the Investment Company Institute (ICI) and the Managed Funds Association did not support the ESG disclosure rules for money managers proposed by the SEC on May 25th. The Investment Company Institute took issue with the requirement for some funds to disclose portfolio emissions, while the Managed Funds Association warned the Commission against adopting an “overly prescriptive” approach.
In May 2022 the Investment Company Institute, American Council of Life Insurers, AllianceBernstein, and Insight Investment submitted comments in response to the Department of Labor’s request for input on Possible Agency Actions to Protect Life Savings and Pensions from Threats of Climate-Related Financial Risk. The entities did not support a requirement for retirement plans to disclose climate risks and did not support a requirement for plan fiduciaries to consider climate risk in decision making.
In a May 19th press release, the National Association of Manufacturers (NAM) stated it is “mobilizing to defend manufacturers” in response to the Securities & Exchange Commission’s (SEC) climate disclosure rule. NAM argued that disclosure should be "less prescriptive, more flexible and solely based on materiality". Meanwhile, The American Farm Bureau Federation released an "Action Alert" calling on farmers to submit oppositional comments to the SEC through an application on their website. Finally, on May 10th, Grantt Bedford, Director of Safety, Environment and Quality at Eni US, submitted a comment to the SEC opposing its proposal on climate change disclosures.
On the 5th May, Aviva and WWF released a joint paper calling for net-zero by 2050 to be a statutory secondary objective for UK financial regulators.
In a meeting with President Biden on March 21st, J.P. Morgan Chase CEO Jamie Dimon urged the White House to create a “Marshall Plan” to scale up US oil and gas production in response to the Russian invasion of Ukraine.
Following the release of the US Securities and Exchange Commission's proposed rule-making on climate change disclosures, the US Chamber of Commerce published a press release on March 21st, in which it argued that the proposal was too “prescriptive” and that voluntary reporting was sufficient to meet investor demand.
An InfluenceMap Freedom of Information Request found emails from November 2021 between U.S. Bancorp and the West Virginia Treasurer that show evidence of U.S. Bancorp communicating its support for continued investments in fossil fuels.
On February 17, the US Chamber held a webinar where it stated opposition to the SEC requiring Scope 3 emissions disclosures in its upcoming rule. This is happening in the midst of an ongoing debate amongst Democratic SEC Commissioners about the appropriate level of ambition for the rule.
In a letter to the Senate Banking Committee, the Chamber raised concerns about the Nomination of Sarah Bloom Raskin to the Federal Reserve on the basis of her opinions around integrating climate risk into policy
In a January 2022 press release, the Association for Financial Markets in Europe (AFME) opposed European Parliament amendments which would make reporting requirements under the EU Green Bond Standard mandatory for all green bonds issued in the EU
In a tweet following the publication of the first delegated act under the EU’s taxonomy regulation, BusinessEurope appeared to call for a weakening of the taxonomy to include gas and nuclear power generation. They stated that “Investments in all zero- and low-carbon energy sources and solutions necessary for the transition must now be integrated into the #taxonomy”
Meeting minutes from May 2021, accessed through FOIs, reveal that BusinessEurope has been lobbying the European Commission to weaken corporate disclosure requirements under the taxonomy. In a meeting with DG FISMA, minutes show that BusinessEurope lobbied for weaker standards, raising concern about the “granularity and scope” of the obligations. In a separate meeting with Ursula von der Leyen’s office, BusinessEurope called for a delay to implementation and questioned the legal basis of aspects of the policy.
A number of US companies and industry associations have met with SEC officials over the past month to discuss proposed action by the regulator on climate change disclosures.
In a September 7th response to the assertion by 19 state attorney generals that BlackRock is sacrificing returns to pursue a “climate agenda”, the asset manager contested this characterization and wrote that it was “disturbed by the emerging trend of political initiatives that sacrifice pension plans’ access to high-quality investments - and therefore jeopardize pensioners’ financial returns.”
On August 24th, after the Texas Comptroller published a list of firms and funds that are banned from doing business with the state because they “boycott” energy companies, the Investment Company Institute issued a press release criticizing this action and urged lawmakers to “prioritize Texas families over partisanship.”
In July 29th responses to the International Sustainability Standards Board’s (ISSB) Climate and Sustainability Disclosure Exposure Drafts, several financial groups expressed concern with the ISSB's proposed Scope 3 emissions disclosures, and encouraged regulators to take a more flexible approach toward Scope 3 disclosure requirements. These include: BlackRock, State Street, Investment Company Institute, the American Bankers Association, the Bank Policy Institute, and Vanguard.
In a July 6th response to a consultation on climate risk by the global Financial Stability Board (FSB), Insurance Europe questioned the FSB’s position that climate change poses a systemic risk to the insurance sector and appeared to caution against potential macroprudential measures.
In an American Petroleum Institute (API) blog post from July 8th 2022, the association appeared to support the inclusion of fossil gas in the EU Taxonomy.
In a letter to Members of the European Parliament (MEPs) on 23rd June, BusinessEurope advocated for the weakening of the EU taxonomy by urging MEPs to support the complementary delegated act that would add certain gas and nuclear activities to the taxonomy.
In a June 16th letter to the U.S. Securities and Exchange Commission (SEC), the US Chamber of Commerce questioned the need for the climate disclosure rule and argued that the SEC does not have the legal authority to propose the rule.
In a June 13th comment letter to the US Securities & Exchange Commission (SEC), the Independent Petroleum Association of America urged the Commission to withdraw its proposed climate disclosure rule, writing that the rule would be “utilized by anti-fossil energy lobbyists to pursue their agendas.”
In a June 7th press release, the National Association of Manufacturers (NAM) stated that it was “pushing back” against the U.S. Securities and Exchange Commission's (SEC) climate change disclosure rule. In particular, it stated opposition to disclosure of scope 3 emissions, auditing requirements and advocated for the weakening of climate-risk disclosures. In an interview with CNBC on June 1st, NAM CEO Jay Timmons argued that small companies could not afford the rule in a time of “record inflation and supply chain shortages and worker shortages”.
In a June 3rd comment to the Federal Deposit Insurance Corporation, Truist encouraged flexibility in climate risk management regulation and emphasized that emerging data and methodologies limit the usefulness of scenario analysis and other risk management strategies. Truist also asked the Corporation to reconsider a proposed provision to require financial institutions to mitigate the impact that risk management has on the broader economy.
At a May 2022 Aspen Institute event, NextEra Energy CEO, Rebecca Kujawa, appeared to support the U.S. Securities and Exchange Commission's (SEC) proposed climate disclosure rule because it would push companies to buy renewable energy. Kujawa stated that utilities would have a “whole new customer base that’s going to be excited about decarbonization” which would present “trillions of dollars of investment opportunity.”
In May 16 comments to the Department of Labor in response to its request for input on Possible Agency Actions to Protect Life Savings and Pensions from Threats of Climate-Related Financial Risk, the US Chamber of Commerce argued that the agency did not have the authority to require fiduciaries to consider climate risk in decision making or disclose how they consider climate risk in decision making.
In May 2022 responses to the Department of Labor’s request for information on Possible Agency Action to Protect Life Savings and Pensions from Threats of Climate-Related Financial Risk, the American Bankers Association (ABA), the American Retirement Association (ARA), and Securities Industry and Financial Markets Association (SIFMA) stated opposition to regulatory action to require fiduciaries to consider climate risk in retirement plan decision making.
In a May 6th 2022 article from German media outlet Tagesschau, BlackRock Investment Strategist, Martin Lück, appeared to oppose the weakening of the EU’s taxonomy to include natural gas.
Following the release of the SEC’s proposed rule-making on climate disclosures, the Investment Company Institute published a press release on March 21st in which CEO Eric J. Pan stated support for the proposal.
In a March 21st press release, the American Petroleum Institute (API) did not appear to support the US Securities and Exchange Commission's proposed rule on climate change disclosures. API argued that it would “create confusion for investors and capital markets”.
Emails from January 2022 obtained by an InfluenceMap Freedom of Information Request show evidence of BlackRock communicating support for continued investment in oil and gas to Texas regulators.
Republicans on the Senate Banking Committee are obstructing the nomination of Sarah Bloom Raskin to the Federal Reserve, along with four other Federal Reserve nominees. This opposition follows a letter sent to the Committee by the US Chamber that raised concerns about Bloom Raskin’s past criticisms of lending to fossil fuel companies.
The American Property Casualty Insurance Insurance Association stated opposition to a California bill that would require insurance companies to disclose investments in and underwriting of fossil fuel-related entities and would authorize the insurance commissioner to prohibit or restrict fossil fuel-related investments and underwriting. A spokesman for the organization called the California bill “unnecessary and potentially dangerous.”
The Institutional Investors Group on Climate Change (IIGCC) published an open letter heavily criticizing the European Commission’s proposal to weaken the taxonomy regulation by allowing some natural gas to be considered ‘green’
The US Chamber of Commerce (the Chamber) issued a press release calling for the reversal of newly issued Securities and Exchange Commission (SEC) guidance on shareholder proposals. The guidance makes it more difficult for companies to exclude shareholder proposals that deal with environmental, social, and governance issues, which the Chamber characterized as the SEC siding with a “small minority of activists” and turning shareholder meetings into “political debate societies.”
EU industry associations including IOGP, FuelsEurope and Cefic are calling for a delay to taxonomy-related corporate reporting requirements. They are also opposing requirements to explain why activities are not compliant with the taxonomy, for example where they significantly harm environmental objectives or do not comply with minimum social safeguards.
In an interview with Fox Business on September 6th, BlackRock Chairman and CEO, Larry Fink, asserted that “in any ESG or any energy transition” gas would “play a central role for the next 50 years.”
On August 17th, financial industry associations including the American Bankers Association, the Bank Policy Institute, and the Securities Industry and Financial Markets Association sent a joint letter to the California State Assembly outlining their opposition to SB 260, the Climate Corporate Accountability Act. The associations urged lawmakers to halt the bill, which would require companies doing business in California to disclose Scopes 1, 2, and 3 greenhouse gas emissions.
In an August 2 Politico newsletter, a spokesman for the American Bankers Association (ABA) expressed concern with California SB 260, a bill that would require companies to disclose greenhouse gas emissions including Scope 3 emissions. The bill is scheduled for a hearing in the California Assembly Appropriations Committee on Wednesday, August 3.
In a June 30th response to a consultation on climate risk by the global Financial Stability Board (FSB), the US Chamber of Commerce opposed the need for regulatory intervention on climate risk broadly, as well as specifically opposing Scope 3 disclosure requirements and macroprudential measures. The Chamber also described the timeframe for reaching net-zero as “30-50 years”.
In a 4th July position paper, the European Banking Federation (EBF) opposed the EU Parliament’s proposal for a mandatory EU Green Bond Standard, stating that a “voluntary standard, as initially proposed by the European Commission, will better serve the growth of the green bond market and the EU GBS will likely find wide acceptance without being established as a mandatory standard”.
In June 17th letters to the U.S. Securities and Exchange Commission (SEC), BlackRock and State Street outlined several objections to the Commission’s proposed climate disclosure rule, not supporting the inclusion of financial statement metrics requirements, Scope 3 disclosure requirements, and certain governance and strategy disclosure requirements. On the same day, in a letter to the SEC, Bank of America outlined several areas of objection to the Commission’s proposed climate disclosure rule, including the financial statement metrics requirements and certain governance and scenario analysis disclosure requirements. Bank of America also recommended an extended period for implementation and an expansion of safe harbor provisions. In the previous day, in a letter to the SEC, the Investment Company Institute outlined significant objections to the Commission’s proposed climate disclosure rule, including the proposed financial statement metrics requirements, Scope 3 disclosure requirements, and certain governance and strategy disclosure requirements.
On June 17th, in a letter to the SEC, the American Chemistry Council stated opposition to the Commission’s proposed climate disclosure rule and requested the rule be withdrawn, calling it “legally unsupportable.”
In a May 26th joint letter to the California Assembly Natural Resources Committee, industry associations including the American Bankers Association, the American Council of Life Insurers, the American Property Casualty Insurance Association, and the National Association of Mutual Insurance Companies stated opposition to California Senate Bill 260, the Climate Corporate Accountability Act. The bill would require businesses to disclose Scope 1, 2, and 3 greenhouse gas emissions and ensure these disclosures have been verified by an independent auditor.
In a statement on June 8th, Allianz board member and chair of the Net Zero Asset Owner Alliance, Günther Thallinger, stated strong support for the SEC’s proposed rule on climate change disclosures and called for increased ambition in some areas of the rule.
In June 3rd comments to the Federal Deposit Insurance Corporation, financial industry associations including the Bank Policy Institute, the American Bankers Association, the US Chamber, and the Securities Industry and Financial Markets Association did not support prescriptive climate-related risk regulation for large financial institutions and asked for flexibility in final rule language.
On May 16 comments to the Department of Labor in response to its request for input on Possible Agency Actions to Protect Life Savings and Pensions from Threats of Climate-Related Financial Risk, TIAA encouraged the Department to finalize its 2021 rule on ESG investing to give fiduciaries greater confidence when considering ESG factors in decision-making, but did not support requiring plan sponsors to disclose climate data.
In a May 16th press release, Association for Financial Markets in Europe (AFME) supported the compromise at the EU Parliament regarding the EU Green Bond Standard, by which it will remain as a voluntary standard. AFME has further pushed for the standard to exclude requirements for transition plans.
In an American Bankers Association (ABA) Banking Journal podcast on May 11, ABA executives questioned the value of the proposed SEC climate disclosure rule, advocating for increased flexibility in the rule and more time for implementation.
On April 8th, Bank of America expressed support for the Securities and Exchange Commission’s proposed climate disclosure rule, emphasizing that Scope 3 disclosures should not be immediately required.
Following the release of the US Securities and Exchange Commission's (SEC) proposed rule-making on climate disclosures, the Bank Policy Institute published a press release on March 21st arguing that the proposal was “overly ambitious”, and urged the SEC to move forward in a more measured way.
Letters submitted to the Texas Municipal Advisory Council and accessed by InfluenceMap in January 2022 show evidence of Barclays, Citigroup, RBC, UBS, U.S. Bancorp, and Wells Fargo stating continued support for investing in fossil fuels. The letters certify that the institutions have pledged to not “boycott energy companies.”
In comments to the Basel Committee on Banking Supervision (BCBS) consultation on climate-related financial risks, the European Banking Federation (EBF) has argued for a more gradual implementation of the integration of ESG into prudential regulation, has suggested that more data is still needed on the impact of climate change, and also appeared to advocate against stress testing leading to changes in capital requirements.
In response to a Bank of England analysis which indicated that climate risks could be as severe as the 2007-2009 financial crisis, the Bank Policy Institute published a blog post suggesting that this analysis was overstating the risk. They argue that “there is a concern that banking regulators may be tempted to make those scenarios more severe in somewhat arbitrary ways.”
Comment letters released in January 2022 show that the US Chamber, the National Association of Manufacturers, the Investment Company Institute, State Street Global Advisors, and Fidelity are among several trade associations and companies that asked the Biden administration’s Department of Labor to weaken language and remove references to ESG considerations from proposed “Prudence and Loyalty” regulation. The proposal reverses Trump-era guidance that sought to limit ESG investing and rollback shareholder rights.
The National Association of Manufacturers (NAM) wrote to the Securities and Exchange Commission (SEC) to express its concerns with the SEC’s recent sample letter to companies regarding climate change disclosures. The NAM cautioned the SEC against imposing new reporting requirements without following the rulemaking process and warned against extending into the “policymaking realm.”
The Institutional Investors Group on Climate Change (IIGCC) and a number of its members co-signed a letter asking the UK’s Prime Minister to commit to a net zero financial sector ahead of the G7 summit in June.
Despite a growing consensus among financial regulators that climate change poses significant risks to the insurance sector, industry associations representing the largest US insurance companies have been actively engaged in efforts to weaken and delay emerging climate-related insurance regulation...
A comprehensive assessment of the world's 30 largest listed financial institutions shows a clear disconnect between the concrete short-term targets and actions needed to address the climate emergency and the limited, long-term targets currently being set by the financial sector. This research see...
The industry group is at odds with investors and its finance sector members on emerging US disclosure requirements
Despite the CA100+ initiative having clear expectations on Paris-aligned lobbying, only 2 of the 31 CA100+ target companies found to be engaging on the taxonomy appear to be supportive of its science-based guidance with 4 companies advocating mixed or unclear positions, leaving more than 80% push...
European companies backing robust, science-based regulation on CO2 emissions under the EU Sustainable Finance Taxonomy are also performing better on stock markets when compared with their peers that are opposing the same policy, according to analysis of InfluenceMap's policy position scores and f...
In the final year of the Trump Administration, authorities finalized three rules which have the effect of limiting the opportunities for ESG (Environmental, Social and Governance) investing.
New analysis from InfluenceMap has tracked significant lobbying on the EU Ecolabel since late 2018, as part of a wider ongoing research process covering the EUs Sustainable Finance Action Plan and how the corporate sector is influencing the process.
The following briefing focuses on how Japanese industry associations lobbied the Taxonomy and considers how these lobbying positions contrast with those of some leading European financial institutions.
An analysis of how business has sought to influence this key EU policy
