A Roadmap to Proposed ESG Disclosures on Form ADV

A significant focus of SEC Chair Gary Gensler’s ambitious rulemaking agenda has been on climate change and environmental, social and governance (ESG) investment factors. In March 2022, the SEC proposed climate risk disclosure rules for public companies. In May, the agency proposed enhanced ESG disclosure rules for certain advisers and registered investment companies and, separately, amendments to the requirements governing the names of registered investment companies. A recent Akin Gump program examined the key provisions and broad sweep of the ESG disclosure proposal; its applicability to, and impact on, private fund advisers; and significant concerns about the proposed disclosure regime. The program featured Akin Gump partners Brian T. Daly, Katherine R. Goldstein and Stacey H. Mitchell. This article synthesizes their comments. See our two-part coverage of the SEC’s proposed corporate climate risk disclosure rules: “Five Key Elements” (May 19, 2022); and “Implications, Challenges, Timing and Pushback” (May 26, 2022); as well as “Deputy Director of SEC Division of Investment Management Discusses Pending Rulemaking” (May 12, 2022).

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