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1 1 (August 16, 2022)

handle is hein.amenin/aeiaeko0001 and id is 1 raw text is: AMERICAN ENTERPRISE ~ ~ INSTmUTE Comment to the Securities and Exchange Commission Proposed Rule: Enhanced Disclosures by Certain Investment Advisers and Investment Companies About Environmental, Social, and Governance Investment Practices Benjamin Zycher Senior Fellow, American Enterprise Institute August 15, 2022 Securities and Exchange Commission File No. S7-17-22 RIN 3235-AM96 Submitted through the Securities and Exchange Commission Portal: https://www.se '. \gov/cgi-b S/r ng- meNnts This comment is submitted to the Securities and Exchange Commission on the proposed rule Enhanced Disclosures by Certain Investment Advisers and Investment Companies About Environmental, Social, and Governance Investment Practices. It is organized as follows: Summary I. The Example of Blackrock. II. The Pursuit of ESG Definitional Consistency Will Harm Investors. III. Observations on ESG Investing As An Artificial Constraint. IV. Market Competition As the Proper Source of the Relevant Definitions. V. The Proposed Greenhouse Gas Disclosure Requirement Is Sophistry. VI. Conclusions. ' The proposed rule is at htt s://www.seegov/r4Ies/p ro osed/2022 33-11068, dt. The American Enterprise Institute (AEI) is a nonpartisan, nonprofit, 501(c)(3) educational organization and does not take institutional positions on any issues. The views expressed in this testimony are those of the author.

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