In October 2022, the U.K.’s Financial Conduct Authority released consultation CP22/20 on Sustainability Disclosure Requirements and investment labels. The proposals in CP22/20 cover sustainable investment labels; investor disclosures and reports; naming and marketing restrictions; and distributor-specific rules. The deadline for responses to CP22/20 is January 25, 2023. This guest article by Goodwin attorneys Ajay Pathak, Andrew Henderson, Danielle Reyes and Chris Ormond explains the key proposals set out in CP22/20. It also examines how those rules compare and contrast with the SEC’s proposed rules on environmental, social and governance investment practices and fund names, as well as the E.U.’s sustainable finance legislation. The article concludes with practical action points for fund managers in scope (both now and in anticipation of the future expansion of the regime to overseas funds marketed in the U.K.) and a chart of the expected application dates of the various proposed rules and requirements. For commentary from other Goodwin attorneys, see our two-part series “Establishing and Marketing Private Funds in the E.U. Under AIFMD”: Key Provisions
(Jun. 27, 2019); and Jurisdiction; AIFs and AIFMs; Private Placements; and Reverse Solicitation
(Jul. 11, 2019).