Joint Response to the European Commission Consultation on the Renewed Sustainable Finance Strategy

On July 15, MFA and AIMA submitted a joint letter in response to the European Commission’s consultation on its renewed sustainable finance strategy, which aims to provide a roadmap of new actions to increase private investment in sustainable projects and activities; to support the different actions set out in the European Green Deal; and to manage and integrate climate and environmental risks into the financial system. In response to this consultation, MFA and AIMA provided the following comments:

  1. Sustainable finance should be investor determined as asset managers’ core duty is to meet the objectives and enhance the assets of their investors. Institutional investors are already engaged in dialogues related to sustainability, and public institutions should work to support a market-driven approach.
  2. Market participants are still assessing and working through the changes that were adopted with the first sustainable finance action plan, and any renewed sustainable finance action plan should take into account previously adopted legislation.
  3. International cooperation is needed on sustainable finance and the EU should consider the US approach when making decisions in order to avoid fragmentation and legal conflicts.
  4. There is currently a lack of quality, comparable, and reliable ESG data and policy initiatives should address this data gap and provide flexibility to market participants when data is not available.
  5. Any further sustainable finance policy initiatives should be flexible and proportionate enough to accommodate a broad array of investment strategies.