IOSCO is requesting feedback, until August 15, 2021, on the proposed recommendations on sustainability-related regulatory and supervisory expectations in asset management. The recommendations cover five areas: asset manager practices, policies, procedures and disclosures; product disclosures; supervision and enforcement; terminology; and financial and investor education. The recommendations aim to address various challenges, such as existing gaps in skills and expertise and the risk of fragmentation caused by divergent regulatory approaches. These challenges may further contribute to a lack of comparability for sustainability-related products, creating difficulties for investors’ monitoring and decision-making and, therefore, facilitating greenwashing.
The consultation report on proposed recommendations outlines the types of greenwashing at the asset manager and product levels, describes the different regulatory approaches taken by securities regulators to address sustainability-related risks and opportunities, and provides an overview of the financial and investor education initiatives conducted by regulators. The consultation report further discusses asset managers’ sustainability-related practices and firm-level disclosures, which are broadly categorized into governance, strategy, risk management, and metrics and targets. This categorization is consistent with the recommendations of the Task Force on Climate-related Financial Disclosures (TCFD). The consultation report proposes the following recommendations designed to provide a list of potential areas for regulatory consideration, in line with the domestic regulatory frameworks:
- Asset Manager Practices, Policies, Procedures, and Disclosures. Securities regulators and/or policymakers, as applicable, should consider setting regulatory and supervisory expectations for asset managers in respect of the development and implementation of practices, policies, and procedures related to sustainability-related risks and opportunities, along with the related disclosures.
- Product Disclosures. Securities regulators and/or policymakers, as applicable, should consider clarifying and/or expanding on the existing regulatory requirements or guidance or, if necessary, creating new regulatory requirements or guidance, to improve product-level disclosures to help investors better understand sustainability-related products and material sustainability-related risks for all products.
- Supervision and Enforcement. Securities regulators and/or policymakers, as applicable, should have supervisory tools to ensure that asset managers and sustainability-related products are in compliance with regulatory requirements and enforcement tools to address any breaches of such requirements.
- Terminology. Securities regulators and/or policymakers, as applicable, should consider encouraging industry participants to develop common sustainable finance-related terms and definitions to ensure consistency throughout the global asset management industry.
- Financial and Investor Education. Securities regulators and/or policymakers, as applicable, should consider promoting financial and investor education initiatives relating to sustainability, or, where applicable, enhance existing sustainability-related financial and investor education initiatives.
The consultation report also highlights a clear need to address challenges associated with the lack of reliability and comparability of data at the corporate level as well as the environmental, social, and governance (ESG) data and ratings provided by third-party providers. The recently published report on sustainability-related issuer disclosures addresses data gaps at the corporate level, while a separate IOSCO report, to be published in July, will cover the proliferation of data and ESG ratings providers.
Comment Due Date: August 15, 2021
Keywords: International, Banking, Securities, Disclosures, Sustainable Finance, ESG, Climate Change Risk, TCFD, IOSCO
Dr. Denton provides industry leadership in the quantification of sustainability issues, climate risk, trade credit and emerging lending risks. His deep foundations in market and credit risk provide critical perspectives on how climate/sustainability risks can be measured, communicated and used to drive commercial opportunities, policy, strategy, and compliance. He supports corporate clients and financial institutions in leveraging Moody’s tools and capabilities to improve decision-making and compliance capabilities, with particular focus on the energy, agriculture and physical commodities industries.
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