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.