This is likely to lead to confusion for ERISA fiduciaries and costs to plan savers. As such, we urge you to you to allow the existing guidance to remain in effect and not move forward with a final rule.The Proposed Rule proposes the retention of the “all things being equal” test but adds new and costly record keeping requirements for fiduciaries to document their conclusion that multiple options are equal and that it is, therefore, appropriate to make a decision based on collateral benefits.
They refer to ordinary business and work or study meetings of councils, boards and committees. Below is a chart detailing three examples of traditional ETFs and their ESG counterparts. We are concerned, however, that the remaining components of the proposal create confusion and are likely to cause fiduciaries to believe they are not permitted to consider material ESG factors in their investment analysis.Currently, under the “all else being equal test,” which has been in place since 1994, fiduciaries may select an investment that provides collateral benefits only after they have determined that the risk and return profile of that investment option is substantially similar to that of competing options that would meet the financial needs of the fund. These are our guidelines for public comment periods in local government. By law, agencies must review all public comments received and, while they can categorize similar comments (e.g. SAMPLE COMMENT LETTER FOR PROPOSED STATE REGULATIONS. We are highly concerned that the Proposed Rule inappropriately creates new burdens for fiduciaries under the “all else being equal test” that will lead to unnecessary costs for plan participants. Public hearings and quasi-judicial hearings are governed by different rules. It provides information or relevant answer to the initial inquiry. WITH COMMENTS [Name, Title] [Address] Dear [Name]: We have reviewed the proposed changes to the [State Name] regulations [identify the regulations using the title or description given by the State], received by our office on [Date]. Request letters are a good way of seeking help and you have to craft them well, so that the reader does not feel you are imposing or overbearing. Sample Cover Letter Letter Template . Review the sample reference letters here - including academic references, personal references, and letters asking for a recommendation - to help you write your own. 1503 & 1507. identical chain/form letters), they are required to respond to all Some people might have a certain concern, or they would like to address an issue, therefore, writing a response letter to such … Not only do the ESG funds outperform their counterparts, they foster societal benefits, creating a win-win scenario for investors who are interested in investing their values with ESG.The Proposal’s discussion of the “all things being equal test” is cause for confusion because, while the test was originally developed to guide the consideration of ETIs, and the discussion in the Proposal appears to envision the selection of an ETI investment, the language of the Proposal does not distinguish the application of this test from the broader discussion of ESG integration, inappropriately suggesting that the documentation requirement is necessary whenever ESG factors are considered.As You Sow is promoting corporate accountability through shareholder action and toxics reduction using innovative legal strategies and community grantmaking. Follow these basic guidelines and get inspired by the following Cover Letter Examples to grab the hiring manager's attention and give yourself a better chance of landing an interview. Comments are due no later than July 30, 2020. If you are using public inspection listings for legal research, you should verify the contents of the documents against a final, official edition of the Federal Register. If the Proposed Rule goes into effect, it will undermine fiduciaries’ ability to act in the long-term best interest of their beneficiaries.