Silver’s comment letter on the SEC’s proposed rule to enhance disclosures made by investment advisers and investment companies about their ESG practices was featured in a new Investor Briefing published by the Principles for Responsible Investment (PRI) that looks at the views of 30 different PRI signatories. The full Investor Briefing can be found here and we’ve included an excerpt from Silver’s letter below for reference:
“… an adviser may “consider” an ESG factor for an investment in its fund without an explicit intention to do so, because an E, S, or G risk (e.g., worker health and safety) is deemed relevant when evaluating a prospective investment. However, this evaluation may occur as a result of the manager’s traditional due diligence process, and not promulgated by way of formal ESG-related practices. Based on this fact pattern, the investment vehicle could be improperly categorized as an “Integration Fund” pursuant to the Proposed Rule.” – Silver Regulatory Associates LLC