comment letter

U.S. Impact Investing Alliance Submits Comments on ISSB Work Plan

The U.S. Impact Investing Alliance responded to the “Consultation on Agenda Priorities” issued by the International Sustainability Standards Board (ISSB). The body, which helps set standards on sustainability-related accounting issues for more than 140 jurisdictions worldwide, released inaugural standards on General Sustainability and Climate-Related Disclosure by companies in June 2023. The latest consultation sought to understand the priorities of investors, business leaders and other stakeholders in determining ISSB’s work plan for the next two years.

U.S. Impact Investing Alliance Submits Recommendations to Federal Policymakers on Community Investing Best Practices

The U.S. Impact Investing Alliance writes in support of a cross-agency initiative by the federal government to reflect on their collective role in generating positive economic outcomes for communities, with an eye toward racial equity.

Specifically, the Alliance responded today to a request for information (RFI) from the newly formed Interagency Community Investment Committee (ICIC) on how to improve the impact of federal community investment programs.

U.S. Impact Investing Alliance Supports Latest Regulatory Win for Investor Transparency

The U.S. Impact Investing Alliance expressed support for the latest iteration of the U.S. Securities and Exchange Commission’s (SEC) disclosure agenda to improve transparency for investors. In addition to expressing broad support for the SEC’s objectives to combat greenwashing and equip investors with decision-useful information, the Alliance’s comments focused on ways the Commission could expand the scope and refine certain provisions in the final rule.

U.S. Impact Investing Alliance & Peers Call for a Strengthened and Race-Conscious Community Reinvestment Act

Today, the U.S. Impact Investing Alliance joined many of our peers on the Coalition on Inclusive Economic in supporting the most meaningful update to a foundational community investing policy in nearly 30 years. The Alliance and 15 organizations representing businesses, investors, nonprofits and community lenders submitted comments to the Federal Reserve, Federal Deposit Insurance Corporation (FDIC) and Office of the Comptroller of the Currency (OCC) in response to their joint rulemaking to reform the Community Reinvestment Act (CRA).

U.S. Impact Investing Alliance Signals Support for ISSB Proposals that Lay the Groundwork for Global Convergence on Sustainability Standards

The U.S. Impact Investing Alliance is encouraged by the emerging global standards on sustainability disclosures, and we believe that the International Sustainability Standards Board’s (ISSB) latest actions lay the groundwork for further progress over time. Specifically, the Alliance was pleased to write in support of the ISSB’s exposure drafts on general sustainability and climate-related disclosures.

The Field Calls on the SEC to Prioritize Human Capital Management Disclosures

In partnership with B Lab and nearly 50 investor, business and philanthropic organizations, the U.S. Impact Investing Alliance wrote to SEC Chair Gensler expressing support for the long-awaited rulemaking on corporate human capital management disclosures.

Related: Read more from our President, Fran Seegull, on how impact investors can set the record straight on the state of ESG investing and the policies necessary to promote a fair, efficient and sustainable investment ecosystem.

U.S. Impact Investing Alliance Applauds Banking Regulator’s Guidance on Climate-Related Risks

The U.S. Impact Investing Alliance wrote to the Federal Deposit Insurance Corporation (FDIC) today in support of their draft guidance for large banks managing climate-related financial risks.

Investors and the broader public are relying on financial institutions to account for the significant, systemic risks posed by climate change in a prudent manner.

The FDIC’s guidance helps provide clarity to banks on how to do so and is an important element of a whole-of-government approach for ensuring a future economy that is resilient and strong.

Impact Investors Support SEC’s Leadership on Climate Transparency

Earlier today, the U.S. Impact Investing Alliance submitted comments in support of the U.S. Securities and Exchange Commission’s (SEC) proposed rule to enhance and standardize climate-related corporate disclosures. This represents a historic moment for impact transparency, as investors have long been calling for accessibility to clear, comparable data related to environmental, social and governance (ESG) factors. The Alliance’s comments communicate broad support for the proposal, which is squarely in line with the SEC’s mandate to protect investors, maintain fair and efficient markets and facilitate capital formation.

Department of Labor Seeks to Protect Retirement Savers from Climate-Related Financial Risks

The U.S. Impact Investing Alliance was pleased to respond today to a Request for Information on how the Department of Labor can protect retirement savers from climate-related financial risks. Alongside specific recommendations for further action and research by the Department, the Alliance is calling for a whole-of-government approach to combatting the significant, systemic risks climate change poses to the economy. Read the Alliance’s full comments here.

Impact Transparency on Climate Risks Is Good for Business, Investors and the Economy as a Whole

A group of 60 impact-oriented business and investor organizations raises our collective and enthusiastic support for the SEC’s proposal to require U.S.-listed companies to disclose their exposure to climate risks, following longstanding calls from investors and other stakeholders. See our full comments to the SEC and keep reading to hear from the letter’s signatories directly.

U.S. Impact Investing Alliance Applauds SEC for Protecting Investors’ Proxy Voting Rights

Earlier today, the U.S. Impact Investing Alliance submitted comments to the Securities and Exchange Commission (SEC) in support of their proposed amendments to the rules governing proxy voting advice for shareholders.

The proposal would rescind a provision finalized in 2020 that undermined the independence of the proxy advisory process. In doing so, the SEC is rightly course correcting and ensuring that investors have access to timely, accurate and unbiased advice, a core element of their shareholder engagement rights.

U.S. Impact Investing Alliance Applauds Critical Step Toward an Improved CRA

The U.S. Impact Investing Alliance applauds the Office of the Comptroller of the Currency (OCC) for its issuance of a final rule yesterday rescinding the 2020 Community Reinvestment Act (CRA) rule from the previous administration. Alongside our peers, the Alliance has submitted several comments to the Federal Reserve, Federal Deposit Insurance Corporation (FDIC) and the OCC expressing the need for the agencies to work collaboratively to uphold the CRA’s core purpose and to better address racial disparities in lending.

Coalition on Inclusive Economic Growth Members Write in Support of Department of Labor Affirmation of ESG Materiality Under ERISA

The U.S. Impact Investing Alliance, along with over 20 other members of the Coalition on Inclusive Economic Growth, comprised of businesses, investors and nonprofits, submitted a letter in support of the Department of Labor’s (DOL) proposed rules clarifying retirement and pension plan fiduciaries’ use of environmental, social and governance (ESG) factors under the Employee Retirement Income Security Act (ERISA).

Group of 30 Organizations Committed to Inclusive Economic Growth Write in Support of Strengthened CRA

The U.S. Impact Investing Alliance, along with 29 organizations, representing businesses, investors, community lenders and advocates, and aligned around the principles of inclusive economic growth, submitted a letter in support of the Office of the Comptroller of the Currency’s (OCC) proposal to rescind June 2020 changes to Community Reinvestment Act (CRA) regulations that would – if fully implemented – significantly weaken the policy. The signatories applauded the OCC’s decision to pursue a cohesive set of reforms that will modernize and strengthen the CRA alongside its peer regulating agencies - the Federal Deposit Insurance Corporation (FDIC) and the Federal Reserve.

U.S. Impact Investing Alliance Applauds Most Recent Progress Toward CRA Reform Alignment

The U.S. Impact Investing Alliance applauds the Office of the Comptroller of the Currency (OCC) for proposing to rescind a rule from the previous administration that would have significantly weakened the Community Reinvestment Act (CRA). If left to stand, the rule would have jeopardized a critical policy for driving capital to underserved communities at a time when stability is paramount given ongoing challenges such as the COVID-19 pandemic and ensuing economic downturn, systemic racism and the climate crisis.

U.S. Impact Investing Alliance Applauds Step Toward Impact Transparency in Congress

On June 16, 2021, the U.S. House of Representatives passed H.R. 1187, a package of legislation that would require the SEC to mandate disclosures by public companies on environmental, social and governance (ESG) factors, climate risks, political spending and other issues. Taken alongside the SEC’s interest in climate and ESG disclosure, this represents a significant moment for investors and other stakeholders seeking greater transparency in the capital markets.

U.S. Impact Investing Alliance Writes to SEC in Support of Mandated ESG Disclosure

The U.S. Impact Investing Alliance submitted comments earlier this week in support of mandated climate and ESG disclosures by the U.S. Securities and Exchange Commission (SEC). The Alliance was responding to a March request for public input by Commissioner Allison Herren Lee that is expected to set the stage for future rulemakings.

U.S. Impact Investing Alliance Applauds Progress Toward Reaffirming the CRA

The U.S. Impact Investing Alliance is encouraged by the Office of the Comptroller of the Currency’s (OCC) announcement yesterday that they will reconsider the harmful regulatory changes to the Community Reinvestment Act (CRA) that were rushed through during the previous administration. The Alliance urges the OCC to leverage this action as the first step in joining with the Federal Reserve in their CRA reform efforts.

U.S. Impact Investing Alliance Supports Nasdaq Proposal on Board Diversity

Last week, the U.S. Impact Investing Alliance submitted comments to the SEC in support of a proposal from Nasdaq related to board diversity and disclosure. Countless studies have shown that gender and racial diversity can drive positive business performance, and investors are increasingly demanding access to clear and comparable data on these and other material issues. If approved by the SEC, all Nasdaq-listed companies would be required to have at least one female board member as well as one member who self-identifies as an “underrepresented minority or LGBTQ+.” Additionally, companies would be required to report on their board composition in a standardized manner.