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ARA Comment Letter to EBSA on Possible Agency Actions to Protect Life Savings and Pensions from Threats of Climate-Related Financial Risk (PDF)
American Retirement Association [ARA] 
[Opinion] May 17, 2022 "The Department's efforts to comply with the Executive Order should focus on ensuring that ERISA plan fiduciaries have prudent processes in place for analyzing all financial risks, including climate-related financial risk, if relevant. The Department should not require ERISA plans to report information relating to climate-related financial risk because it has not explained its rationale or expectations for how doing so would support its mandate to supervise and enforce ERISA, and it will increase administrative burdens on plans and service providers." |
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