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Florida's Latest Anti-ESG Efforts

Today, Governor DeSantis (R-FL) signed into law an anti-ESG bill that, among other things, bars managers of the state's pension fund from considering ESG factors when making investments.  Instead, pecuniary factors are the...more

SEC Commissioner Voices Strong Support for Proposed SEC Climate Disclosure Rule and Related Proposed ESG Disclosure Rules

SEC Commissioner Lizarraga, one of the recent Democratic appointees to the Securities & Exchange Commission, delivered a speech on April 18 at the annual public policy symposium of the North American Securities Administrators...more

Energy & Sustainability Litigation Updates — March 2023

State and Local ESG Regulation. Despite recent public statements by notable Republican federal officials, including an SEC Commissioner, that have expressed considerable skepticism towards the SEC’s proposed ESG...more

President Biden Issues First Veto to Protect ESG Investing

Today, President Biden issued the first veto of his presidency. This action had been heavily telegraphed in advance and was widely expected. Nonetheless, this veto is extraordinarily significant....more

SEC Continues Focus on ESG Issues in 2023 Examination Priorities

Last month, the SEC issued its list of examination priorities for 2023. Among the list of six priorities identified by the SEC in its press release was "Environmental, Social, and Governance (ESG)." Specifically, the SEC...more

SEC Commissioner Uyeda Suggests that ESG Disclosures Contribute to Decline in IPOs

In a recent lecture delivered at Columbia Law School/Business School at the "Going Public in the 2020s" conference, SEC Commissioner Uyeda bemoaned "the general decline in the number of public companies over the past...more

President Biden Threatens First Veto Over Congressional Nullification of DOL Regulation Enabling Consideration of ESG Factors

Last fall, the Biden Administration's Department of Labor ("DOL") issued a regulation ("Prudence and Loyalty in Selecting Plan Investments and Exercising Shareholder Rights") that, according to a White House press release,...more

Antitrust Practitioners Expect Activity With Climate Issues

As we have noted previously, a number of Republican politicians had previously identified antitrust law as a potential counter to ESG efforts, particularly if companies began to coordinate a response to climate change. Even...more

Conflict in Kentucky Over ESG Investing

The State of Kentucky, like many other states across the country, is now engaged in significant conflict over the politicized issue of ESG investing. Last spring, the Kentucky legislature passed a bill ordering that the...more

Republican Congressmen Announce ESG Working Group To Counter Federal ESG Regulations

Last week, the Chairman of the House Financial Services Committee, Patrick McHenry (R-NC), "announced the formation of a Republican Working Group" composed of nine (9) Republican congressmen and "led by Oversight and...more

California Legislators Propose Three Climate Bills Focused on ESG Disclosure and Investment

Three bills have recently been proposed by a trio of California state legislators concerning ESG financial disclosures and investing. The first, SB 253, would "require all large corporations that do business in California to...more

SEC Commissioner Questions ESG Investing

Last week, SEC Commissioner Uyeda delivered an address in which he "focus[ed] on issues related to asset managers' use of environmental, social, and governance (ESG) investment strategies." While his talk addressed many...more

Florida CFO Bans ESG Investing By Florida Deferred Compensation Plan

This week, Florida CFO Patronis directed "all participating asset managers to remove ESG investment funds as options for participants in the Deferred Compensation Plan." In effect, Patronis has now barred investments in ESG...more

Texas AG Bars Major Bank from Underwriting Municipal Bond Offerings in Texas Due to Alleged Discrimination Against Firearms...

Last week, it was reported that the Texas Attorney General would "not approve any public security" which was purchased or issued by a major bank due to alleged discrimination against the firearms sector. In 2021, Texas had...more

Caremark Liability Following the SEC’s New ESG Reporting Requirements

Recent developments in the Court of Chancery concerning a corporate board’s duty to monitor and provide oversight over a corporation’s operations, so-called Caremark claims, are likely to intersect with the Securities and...more

Ratings Agencies Increase Focus on "Green Ratings"

S&P recently purchased Shades of Green, which has been described as "the largest external reviewer of sustainable bond and green financing frameworks." This acquisition emphasizes the recent strategic move by major ratings...more

Energy & Sustainability Litigation Updates — December 2022

SEC Enforcement: In its yearly summary of enforcement activity, the SEC chose to highlight ESG-related issues as one of only a handful of subject matter areas that the SEC is focused on, indicating the significant priority...more

SEC Highlights ESG Enforcement Activity in Annual Report

The SEC recently announced its yearly summary of enforcement activity. Among the items it chose to highlight were its efforts to enforce ESG-related issues. ESG was one of only a handful of subject matter areas that the SEC...more

Department of Labor Enables Consideration of ESG Factors in ERISA Investments

Yesterday, the Department of Labor "released a final rule under the Employee Retirement Income Security Act (ERISA) . . . [that] clarif[ied] that fiduciaries may consider climate change and other environmental, social, and...more

Senate Republicans Issue Warning to Law Firms About Potential Antitrust Implications of ESG Activities

Last Thursday, five Republican senators--Cotton (AR), Grassley (IA), Rubio (FL), Lee (UT), and Blackburn (TN)--sent an identical letter to approximately fifty (50) major U.S. law firms, in which they stated that law firms...more

SEC States That Considering Diversity When Recommending Investment Advisers Is Consistent With An Advisor's Fiduciary Duty

Earlier this month, the SEC issued an FAQ concerning "an adviser's fiduciary duty when considering factors relating to diversity, equity, and inclusion (DEI) in the selection or recommendation of other investment advisers."...more

Energy & Sustainability Litigation Updates — October 2022

Regulatory Developments Among State AGs. Over the past few weeks, various state attorneys general have either issued guidance or initiated enforcement actions in connection with ESG ratings. Specifically, among other things,...more

Public Criticism of Ratings Used for ESG Investing

Today's edition of the New York Times featured an opinion piece that critiqued ESG investing--and not from the perspective that "values" investing is economically counter-productive. (For that viewpoint, the editorial page...more

Republican SEC Commissioner Peirce Questions Proposed SEC Rule Concerning ESG "Greenwashing"

In remarks delivered today to the SEC Investor Advisory Committee, SEC Commissioner Pierce--one of the Republican appointees to the Commission--offered a critique of the proposed SEC rule re: "greenwashing," which is the...more

Republican Senators Press Judicial Nominee to Third Circuit on ESG Issues

During the Senate Judiciary Committee's hearing on the nomination of Delaware Supreme Court Justice Montgomery-Reeves to the Third Circuit Court of Appeals, certain Republican Senators, including Grassley (R-Iowa) and Lee...more

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