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American Bankers Association Comment Letter to DOL in Response to RFI on Possible Agency Actions to Protect Life Savings and Pensions from Threats of Climate-Related Financial Risk
American Bankers Association
[Opinion] May 10, 2022 "[S]ingling out climate-related financial risk for mandatory consideration and reporting, regardless of the actual presence or degree of its risk, [1] undercuts a plan fiduciary's authority and duty under ERISA to appropriately consider and manage all relevant risks, [2] imposes unnecessary costs to plans and their participants, and [3] undermines ERISA standards and Department regulations on investment duties that require deference to the judgment of the plan fiduciary rather than the substitution of the Department's judgment." MORE >> |
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