Department of Labor Proposal on ESG—Selected Comment Letters

The U.S. Department of Labor (DOL) sought comments, due July 30, 2020, on proposed amendments to the “investment duties” regulation under Title I of the Employee Retirement Income Security Act of 1974 (ERISA). The amendments seek to confirm that ERISA plan fiduciaries select investments and investment courses of action based solely on financial considerations relevant to the risk adjusted economic value of a particular investment or investment course of action.
 
The DOL has posted comment letters here.
 
CII’s comment letter is here.
 
Comments by CII members that the DOL had posted as of August 4 are linked below:
 

Amalgamated Bank Ivan Frishberg July 30, 2020 American Federation of Labor and Congress of Industrial Organizations AFL-CIO Brandon J. Rees, Alex Roe July 30, 2020 American Federation of State, County and Municipal Employees AFSCME Dalia Thornton July 30, 2020 American Federation of Teachers Randi Weingarten July 30, 2020 As You Sow Andrew Behar July 30, 2020 Australian Council of Superannuation Investors Louise Davidson July 30, 2020 Baillie Gifford Overseas Limited Suzanne Quinn July 30, 2020 BlackRock, Inc. Barbara Novick, Anne Ackerley, Brian Deese, Nicole Rosser July 30, 2020 BMO Global Asset Management Kristi Mitchem July 30, 2020 BNY Mellon Investment Management Mitchell E. Harris July 29, 2020 California State Teachers’ Retirement System Aeisha Mastagni July 30, 2020 Calvert Research and Management John Streur July 30, 2020 Capital Group Jason Bortz July 30, 2020 Ceres Mindy S. Lubber July 30, 2020 Illinois State Treasurer Michael W. Frerichs July 30, 2020 Impax Asset Management LLC Joseph F. Keefe, Julie Fox Gorte July 28, 2020 Institutional Shareholder Services, Inc. Gary Retelny July 22, 2020 International Brotherhood of Teamsters Ken Hall July 29, 2020 Lazard Asset Management LLC Nikita Singhal, Jennifer Anderson July 30, 2020 Legal & General Investment Management America, Inc. Aaron Meder July 24, 2020 Lord, Abbett & Co. LLC Robert A. Lee July 30, 2020

Maryland State Retirement and Pension System R. Dean Kenderdine July 24, 2020 Minnesota State Board of Investment Mansco Perry III July 30, 2020 Montgomery County (Maryland) Employees’ Retirement System and the Montgomery County Consolidated Retiree Health Benefits Trust Linda Herman July 30, 2020 MSCI Inc. Remy Briand July 30, 2020 Parnassus Investments Benjamin E. Allen July 29, 2020 Putnam Investments Robert L. Reynolds July 29, 2020 RBC Global Asset Management Melanie Adams July 30, 2020 San Francisco City and County Employees Retirement System Jay Huish, William J. Coaker, Jr. July 29, 2020 Segal Marco Advisors John DeMairo July 23, 2020 Service Employees International Union Renaye Manley July 30, 2020 Shareholder Commons and B Lab US/CAN Frederick Alexander, Holly Ensign-Barstow July 29, 2020 State Street Global Advisors Lori Heinel, Katherine S. McKinley July 30, 2020 State Treasurer of Pennsylvania Joseph M. Torsella July 24, 2020 Sumitomo Mitsui Trust Asset Management Co., Ltd. July 29, 2020 TIAA Teachers Insurance and Annuity Association of America Amy O’Brien, Yves P. Denize July 30, 2020 T. Rowe Price Associates, Inc. Margaret Raymond July 30, 2020 Vanguard Group, Inc. John James July 30, 2020 Vermont Pension Investment Committee Vermont State Treasurer Elizabeth A. Pearce July 30, 2020 Voya Financial, Inc. Christine Hurtsellers, Charles Nelson July 29, 2020 Wellington Management Company LLP Mary Pryshlak July 30, 2020