Council of Institutional Investors

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