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ESG Investing

Environmental, social and governance (ESG)-focused investing is of increasing interest to investors, plan sponsors and even regulators. 

While numerous studies and surveys suggest that investors are interested in ESG factors and funds that incorporate ESG criteria, there still does not appear to be consistent terminology and standards when it comes to describing ESG integration and sustainable investing strategies.

To help you stay up to date on the latest developments, this resource page includes links to legislative and regulatory documents and NAPA news coverage and commentary, as well as industry analyses, advisories and studies, including white papers and thought leadership content.

Updated Dec. 2, 2022


ARA Comment Letters

Comment Letter to EBSA on Possible Climate-Related Actions (May 16, 2022)

Letter to SEC Responding to its Request for Comments on Climate Change Disclosures (June 10, 2021)

Letter to EBSA on Financial Factors in Selecting Plan Investments Proposed Regulation (July 30, 2020) 


NAPA News Coverage

Browse our news posts and commentary concerning the use of ESG factors in investing.


DOL Guidance

DOL Final Rule: Prudence and Loyalty in Selecting Plan Investments and Exercising Shareholder Rights (Dec. 1, 2022)

DOL News Release Announcing Final Rule on ESG Factors in Plan Investments (Nov. 22, 2022)

DOL Proposed Rule on Selecting ESG Investments in Retirement Plans and Proxy Voting (Oct. 13, 2021)

EBSA News Release on Enforcement Policy for Final Rules on ESG Investments and Proxy Voting (March 10, 2021)

DOL Enforcement Policy Statement on Final Rules on ESG Investments and Proxy Voting (March 10, 2021) 

DOL Final Rule on Fiduciary Duties Regarding Proxy Voting and Shareholder Rights (Dec. 16, 2020)

DOL Final Rule on Financial Factors in Selecting Plan Investments (Nov. 13, 2020)

DOL Proposed Rule on Fiduciary Duties Regarding Proxy Voting and Shareholder Rights (Sept. 4, 2020)

EBSA Collected Comment Letters on Financial Factors in Selecting Plan Investments (July 2020)

DOL Proposed Regulation on Financial Factors in Selecting Plan Investments (June 30, 2020)

DOL Field Assistance Bulletin 2018-01 (April 23, 2018)

DOL Interpretive Bulletin 2016-1 (Dec. 29, 2016)

DOL Interpretive Bulletin 2015-1 (Oct. 26, 2015)


SEC Guidance

SEC Risk Alert on ESG Investing (April 9, 2021)

SEC Resource Page on ESG Investing (March 2021)

SEC Request for Input on Climate Change Disclosures (March 15, 2021)

SEC 2021 Exam Priorities (includes focus on climate and ESG-related risks) (March 3, 2021)

SEC Announcement on Enforcement Task Force Focused on Climate and ESG Issues (March 4, 2021)

SEC Investor Bulletin on ESG Funds (Feb. 26, 2021)

Statement by Acting Chair Allison Herren Lee on Review of Climate-Related Disclosure (Feb. 23, 2021) 


Legislative Documents  

Corporate Governance Improvement and Investor Protection Act (H.R. 1187, approved by U.S. House June 16, 2021))

Sustainable Investment Policies Act (Dec. 14, 2020/May 27, 2021)

Climate Risk Disclosure Act (H.R. 2570, May 20, 2021)  

Financial Factors in Selecting Retirement Plan Investment Act (May 20, 2021) 

Senate Republican Letter Regarding DOL Enforcement Policy Announcement (March 18, 2021)

ESG Disclosure Simplification Act of 2021 (Feb. 18, 2021; see Corporate Governance Improvement and Investor Protection Act above)

Retirees Sustainable Investment Policies Act of 2020 (Dec. 14, 2020)

House Democrat Letter to DOL on Proposed Financial Factors Regulation (July 20, 2020)

Senate Democrat Letter to DOL on Proposed Financial Factors Regulation (July 15, 2020)


Industry Analysis and Commentary

Between a Rock and a Hard Place... ESG Investments in 401(k) Plan Line-Ups (Seyfarth Shaw LLP, May 20, 2022)

Three Barriers to ESG Adoption for U.S. DC Plans (DCIIA, March 2022)

ESG and Participant Communication (DCIIA, March 2022)

6th Annual Responsible Investing Survey (Nuveen, Dec. 16, 2021)

DOL's ESG Proposed Rule: A Retirement Committee's Perspective (Alden Bianchi, Mintz, Nov. 12, 2021)

Feeling Like a Yo-Yo? Latest Swing in ESG Investments and ERISA's Fiduciary Duties (Seyfarth, Oct. 25, 2021)

Labor Dept. Proposal to Clear Way for Retirement Plans to Consider ESG (Aron Szapiro, Morningstar, Oct. 13, 2021)

DOL rules permit ESG TDFs as default option in BlackRock, Natixis products (RIABiz, Oct. 13, 2021)

Pensions and ESG: An Institutional and Historical Perspective (Wharton/Pension Research Council, Sept. 28, 2021)

Incorporating ESG in DC Plans (DCIIA, June 2021)

Current legislation and regulatory outlook: ESG update (October Three Consulting, June 16, 2021)

Sustainable Funds U.S. Landscape Report (Morningstar, February 2021)

The “ABC’s” of ESG (National Law Review, Feb. 8, 2021)

ESG Investing: Momentum Moves Mainstream (J.P. Morgan, Jan. 21, 2021)

Future of Sustainability in Investment Management: From Ideas to Reality (CFA Institute, December 2020) 

DOL Releases Final ESG Rule (October Three, Nov. 9, 2020)

The DOL’s Final ESG Investment Rules May Force Reassessment of “Church Plan Status” for Some Organizations (The Business of Benefits, Nov. 9, 2020)

DOL Shifts Focus from ESG to Pecuniary Factors in Final Rule (Groom Law Group, Nov. 6, 2020)

ESG Incorporation Nearly Doubles in 5 Years; Those Considering It Jumps (Callan, Oct. 8, 2020) 

ESG Investing and Public Pensions: An Update (Center for Retirement Research, October 2020)

Making Sense of ESG Investing (Cammack Retirement, Sept. 29, 2020)

How Does Investing in ESG Companies Affect Returns? (Morningstar, Feb. 19, 2020)

Getting into the ESG Disclosure, Rating and Ranking Game (Seyfarth Shaw, Sept. 1, 2020)

DC Update: Our Take on the DOL Proposed ESG Rule (MFS, July 28, 2020)

Funds’ Use of ESG Integration and Sustainable Investing Strategies: An Introduction (ICI, July 2020)

Sustainable Investing in Defined Contribution Plans A Guide for Plan Sponsors (DCIIA, May 2019)

ESG Investing Survey: Investors Want the Best of Both Worlds (Natixis, May 2019)


Got a favorite resource that's not listed? Share it! Email NAPA Net editor Ted Godbout at [email protected]