The US Department of Labor has issued a proposed update to guidance on the selection of plan investments, which would create barriers to the continued growth of ESG investing. My comments – submitted today – are attached. In short:

(1) the proposal would offer no meaningful new safeguards against inappropriate activity, but rather would shackle good decision-making to the detriment of plan participants;

(2) it’s perfectly possible to give some consideration to non-pecuniary objectives without sacrificing financial goals;

(3) the DOL should adopt the attitude of other regulators around the world, who are acting to encourage (not discourage) a long-term responsible mindset among investors.