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Red State AGs' ESG Antitrust Complaint Against Asset Managers Survives Motion to Dismiss

Last fall, a coalition of eleven Republication attorneys-general filed an antitrust complaint against three major asset managers, alleging that the asset managers' adherence to climate-friendly principles--which discourage...more

Missouri AG Launches Investigation of Proxy Advisory Firms Related to Alleged ESG-Focused Recommendations

The Missouri Attorney-General, Republican Andrew Bailey, recently announced an investigation into the two principal proxy advisory firms for potential violations of Missouri law “related to their promotion of radical...more

Biden Administration's DOL Rule Permitting ESG Investments Survives Legal Challenge

4 Last week, a federal district judge in the Northern District of Texas upheld a rule promulgated by the Biden Administration's Department of Labor enabling ESG-focused investing. Specifically, the court determined that the...more

Federal Court Rules ESG-Guided Investing of 401(k) Plan Is a Breach of Fiduciary Duty

Following a bench trial, Judge O'Connor (N.D. Tex.) held that “that Defendants breached their fiduciary duty by failing to loyally act solely in the retirement plan's best financial interests by allowing their corporate...more

Missouri Abandons Appeal of Court Decision Striking Down State Anti-ESG Rules\

Last month, a federal district court struck down Missouri's anti-ESG rules that would prohibit investment advisors from utilizing ESG factors when making investment decisions (absent written consent of the client). ...more

SEC Disbands ESG Task Force

It has been reported that the Securities & Exchange Commission has disbanded its Climate & ESG Task Force. This same task force had been launched with great fanfare in March 2021, at the beginning of the Biden...more

Federal Court Bars Missouri's Anti-ESG Investment Rules

Yesterday, Judge Bough (W.D. Mo.) issued a decision barring the recent anti-ESG rules Missouri had promulgated that prohibited investment advisers from utilizing ESG factors when making investment decisions (absent written...more

Federal Judge Certifies Class Objecting to ESG Investments by Retirement Fund

On May 22, 2024, Judge O'Connor (N.D. Tex.) ordered that the plaintiffs claiming that investment managers breached their fiduciary duty due to their ESG-focused investing be certified as a class for purposes of the...more

House Democrats Initiate Probe of Anti-ESG Investment Guidelines Issued by Conservative States

On Monday, May 21, 2024, Congressman Nadler (D-NY) and Congressman Correa (D-CA), the ranking Democratic members on the House Judiciary Committee and relevant subcommittee, sent a letter to the Attorney General and Chief...more

Texas Court Rules ESG Lawsuit Against Employer's 401(k) Plan Can Proceed

Recently, a Texas federal court denied the defendants' motion to dismiss in a lawsuit featuring allegations that an employer's 401(k) plan, which allegedly relied on ESG principles when making investments, violated ERISA. ...more

SEC Approves Sweeping New Climate Disclosure Rule: Key Takeaways

The Securities & Exchange Commission ("SEC") issued its long-awaited final rule concerning climate disclosures, entitled “The Enhancement and Standardization of Climate-Related Disclosures for Investors” (“Climate Disclosure...more

Energy & Sustainability Litigation Updates — February 2024

Recently, a pair of bills were proposed in the New Hampshire state legislature that would make it a felony to knowingly invest state or taxpayer funds based upon ESG criteria in violation of fiduciary duty. Specifically, the...more

New Hampshire Legislators Propose Laws to Criminalize Investing Based on ESG Criteria

Recently, a pair of bills were proposed in the New Hampshire state legislature that would make it a felony to knowingly invest state or taxpayer funds based upon ESG criteria in violation of fiduciary duty. Specifically, the...more

Significant ESG Enforcement Action by the SEC Against Major Investment Advisor

On September 25, 2023, the SEC announced a settled administrative proceeding against a major investment advisor in which it agreed to pay a $19 million civil penalty for, effectively, greenwashing activities--i.e., pretending...more

Biden Administration's DOL Rule Enabling Investment Advisors to Consider ESG Factors Survives Judicial Challenge

On September 21, 2023, Judge Kacsmaryk (N.D. Texas), a famously conservative Trump-appointed jurist, upheld a Department of Labor rule promulgated by the Biden Administration that enables employee retirement plans to consider...more

House Financial Services Committee Criticizes ESG Regulations and Activism in Corporate America

Last week, the House Financial Services Committee held a hearing entitled "Protecting Investor Interests: Examining Environmental and Social Policy in Financial Regulation." As indicated by the title of the hearing, the...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

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

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

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

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

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

SEC Chairman Gensler Re-Affirms Importance of Climate Disclosures in Senate Testimony

Today, SEC Chairman Gensler testified before the Senate Committee on Banking, Housing, and Urban Affairs. His remarks were wide-ranging, and touched upon a number of different SEC priorities--but Chairman Gensler made sure...more

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