top of page

ASA Releases ESG Disclosure Resource Index and Raises Questions to Consider

WASHINGTON – The American Securities Association (ASA) today released an ESG Disclosure Resource Index to catalogue a number of recent studies, reports, news articles, as well as statements from policymakers to help inform the Securities and Exchange Commission (SEC) as it considers whether to mandate climate and environmental, social, and governance disclosures for public companies.

“The ASA supports investor choice and access to a wide variety of investments, including ESG products,” said ASA CEO Chris Iacovella. “We also take the political issues surrounding the ESG Disclosure debate very seriously. As a result, we tried to raise some questions the SEC may not have previously thought about and introduce some new information into a discussion dominated by passionate opinions and conflicted market participants.”

In its submission to the SEC, ASA organized the ESG Disclosure Resource Index by: (1) ESG Investment Performance and (2) Costs of Climate and ESG Disclosure.

ASA also raised questions in its letter for the SEC to consider, including:

The SEC’s Mission: How does the SEC prioritize the three prongs of its statutory mission to (1) protect investors, (2) maintain fair, orderly, and efficient markets, and (3) facilitate capital formation. As it relates to ESG Disclosure, it’s not clear which investors the Commission seeks to protect, nor is it clear how increasing the cost of compliance for public companies will facilitate capital formation in the U.S.

Shareholder Priority: The SEC should clearly set forth the legal authority it intends to rely on to place the interests of more vocal activist and institutional investors over those of less vocal retail investors on this issue.

Wall Street-Industrial-Complex or Retail Investors: The SEC should consider who benefits from the creation of a complex and prescriptive ESG Disclosure framework. It appears that an entrenched professional class on Wall Street consisting of ESG standard-setters, ratings firms, well-heeled corporate attorneys, auditors, investment banks, asset managers, proxy advisors, and index providers stands ready to reap a massive monetary windfall from a government mandate of ESG Disclosure. This begs the question: should the SEC use ESG as the reason to adopt a policy that transfers money from the public companies owned by America’s mom-and-pop investors directly to the Wall Street-industrial-complex?

Investment Returns: The SEC should include a discussion in its proposal describing how the returns of long-term retail investors may be impacted if: (1) the cost of public company compliance rises, (2) high-cost ESG products that underperform traditional investment vehicles become the market, or (3) an asset bubble created by ESG products inevitably pops.

Small Business Capital Formation: We suggest the SEC consider delaying ESG Disclosure for small and emerging growth company issuers located in the United States. Taking this action would significantly reduce the cost burdens for those companies, and would not disincentivize capital formation.

No China Exemption: Communist China is the world’s largest emitter of greenhouse gases, pays lip service to the Paris Agreement, and commits egregious “crimes against humanity” and genocide against its own people. Companies from this country must not be able to access our capital markets directly, through index funds or other means unless they too must comply with every U.S. disclosure mandate.

To view ASA’s full letter and ESG Disclosure Resource Index, click here. This Index will be updated on the ASA website as new information becomes available.


ASA’s regional financial services companies work in communities across the country to create jobs, grow the economy, and increase prosperity for all Americans. The ASA exclusively represents the capital market and private client interests of its members and seeks to promote free market principles making it easier to access financial advice and capital. ASA members help Americans save for retirement, provide Main Street businesses with capital to grow, and advise hardworking Americans how to create and preserve wealth. For the latest updates follow @AmerSecurities and learn more at


bottom of page