Policy: Disclosure


Investors are increasingly integrating environmental, social and corporate governance (ESG) information into the investment process. Materiality, or financial relevance, emerges from all the reported facts. Investor efforts to comprehensively incorporate ESG information into investment decisions are hindered by a lack of comprehensive, comparable and reliable data.

One of the key priorities for US SIF and its members is enhanced reporting of corporate ESG information. US SIF supports public policy that promotes the reporting of uniform, consistent, and comparable information on material risks and opportunities. There needs to be more robust and effective disclosure.

Priority Areas of Action

Sustainability reporting: Meaningful sustainability reports are valued by multiple stakeholders, including investors, and should continue to be required to be filed at the SEC by all public companies. Sustainability information provided on company websites alone is not sufficient to address investor needs as it does not permit comparison of consistent, comparable information on material risks and opportunities. Regulation S-K disclosure should be geared towards all types of investors, from the average investor to the sophisticated professional financial analyst. Every segment of the investor community is entitled to have access to information they deem necessary and material –regardless of size, interests and sophistication.
Letters and Statements
US SIF Comment Letter on SEC Climate and ESG Disclosure Request for Information 06/2021
US SIF Written Testimony on ESG Disclosure 07/2019
Joint Report on SEC Disclosure 09/2016
US SIF Comment Letter on Regulation S-K Disclosure 07/2016
US SIF Letter to SEC on Disclosure Effectiveness Review 09/2014
Letter to SEC Chair Mary Jo White and Director Keith Higgins regarding Disclosure Effectiveness Review 07/2014
US SIF Letter to the SEC requesting mandatory ESG disclosure 07/2009