comment letter

U.S. Impact Investing Alliance Submits Comments in Support of Strengthened Community Reinvestment Act

The U.S. Impact Investing Alliance submitted comments to the Federal Reserve earlier today in support of their proposed framework to modernize the Community Reinvestment Act (CRA). A civil rights era policy created to address the racist practice of redlining, the CRA has become the bedrock of the community investing environment here in the United States, lending a stable environment to the place-based work of impact investors.

U.S. Impact Investing Alliance Supports IFRS Foundation Effort on Sustainability Standards

The U.S. Impact Investing Alliance today submitted public comments to the IFRS Foundation in response to the Consultation Paper on Sustainability Reporting. The IFRS Foundation is a not-for-profit international organisation responsible for developing a single set of high-quality global accounting standards, known as IFRS Standards. The Consultation Paper solicits public comment on the proposed creation of a new Sustainability Standards Board (SSB) that would look to promote consistent and comparable corporate reporting on key sustainability issues.

U.S. Impact Investing Alliance Calls for a Suspension to Yet Another DOL Rulemaking Harmful to Retirement Savers

The U.S. Impact Investing Alliance again called on regulators today to suspend an unnecessary and harmful rulemaking effort given the ongoing global health and economic crises. The Department of Labor has proposed a rule that would effectively prohibit ERISA-regulated retirement and pension plan fiduciaries from engaging corporate managers through the proxy vote process, singling out engagement on environmental, social and governance (ESG) issues in particular. The Alliance and many in the field view this proposal as an attack on shareholder engagement and the broader principles of impact investing.

Alliance Opposes Harmful DOL Rule on ESG Investing

The U.S. Impact Investing Alliance submitted a comment letter to the Department of Labor (DOL) today in opposition to the proposed changes to the fiduciary standard for ERISA-regulated retirement plans. The Alliance and its members strongly disagree with the substance of the DOL’s proposal, and we urge regulators to reconsider their foundational assumptions that either lack supporting evidence or are in direct contradiction with broadly accepted investment practices and theories.

Alliance Urges DOL to Pause Disruptive Rulemaking on ESG in ERISA Regulations

In a public comment to the U.S. Department of Labor today, the U.S. Impact Investing Alliance called on regulators to suspend efforts to rewrite the fiduciary standards for ERISA-regulated pensions. The Alliance is concerned that the proposed rule would have a chilling effect on ESG investments by placing an undue burden on fiduciaries considering ESG criteria, despite the fact that ESG metrics often correlate with long-term financial performance. The comment period is scheduled to close on July 30, and given the significant upheaval and distress caused by the COVID-19 pandemic, as well as the complexity of the proposed changes, the Alliance urges the Administration to delay the deadline until well after the crisis has passed.

CRA Reforms Jeopardize Impact Investments in Vulnerable Communities

The U.S. Impact Investing Alliance submitted comments to federal regulators today outlining our substantial concerns with proposed rules to fundamentally overhaul the Community Reinvestment Act (CRA). The proposed changes from the Office of the Comptroller of the Currency (OCC) and the Federal Deposit Insurance Corporation (FDIC) would significantly dilute the CRA, putting billions of dollars of community development activities at risk at a time when American communities need them the most. The Alliance previously submitted comments last month urging regulators to extend the rulemaking until well after the COVID-19 National Emergency is lifted, echoing similar calls from the Presidents’ Council on Impact Investing.

To learn more about the potentially harmful implications of the proposed rules from the OCC and FDIC, click here.

Alliance Calls for CRA Rulemaking Extension Amid COVID-19 Pandemic

The U.S. Impact Investing Alliance submitted comments late last week urging federal regulators to extend the comment period for proposed changes to the Community Reinvestment Act (CRA) given the ongoing health crisis. The Office of the Comptroller of the Currency (OCC) and the Federal Deposit Insurance Corporation (FDIC) have proposed rules that would drastically alter the CRA, a key community development tool that requires banks to be responsive to their communities’ financial needs. While the Alliance plans to submit additional comments on the substance of the proposed rules, the initial comments call for the extension of the current April 8 deadline until 90 days after the National Emergency Concerning the COVID-19 Outbreak is declared over. The Alliance believes that stability for communities and banks right now is paramount as the country grapples with the health and economic impacts of the pandemic.