ISDA Responds to SEC Rule Proposal: ESG Disclosures by Certain Investment Advisers and Investment Companies

On August 16, 2022, ISDA filed the attached comment letter with the U.S. Securities and Exchange Commission (SEC) in response to the agency’s rule proposal regarding ESG disclosures for certain investment advisers and investment companies. The SEC’s proposal addresses a number of issues related to the manner in which funds and advisers incorporate ESG factors in to their investor disclosures. ISDA’s comments are limited to the aspects of the proposal that reference derivatives instruments.

Documents (1) for ISDA Responds to SEC Rule Proposal: ESG Disclosures by Certain Investment Advisers and Investment Companies

Joint Response to EBA Consultation

On August 12, ISDA and the Association for Financial Markets in Europe (AFME) responded to the European Banking Authority’s discussion paper on certain taxonomy key performance indicators (KPIs) and other aspects of the Disclosures Delegated Act  under Article 8 of...

Response to JSCC on Clearing Fund Consolidation

On August 12, ISDA responded to the Japan Securities Clearing Corporation’s (JSCC) consultation on its proposal to consolidate clearing fund consumption, calculation and deposit segmentation across six clearing qualifications under the Financial Instruments and Exchange Act. ISDA members broadly support...

Response on CSDD Guidelines

On August 6, ISDA responded to the European Commission’s (EC) consultation on due diligence guidelines under the Corporate Sustainability Due Diligence Directive (CSDDD). While ISDA acknowledges that model contractual clauses can be a helpful resource for in-scope companies, there are...