Comment Letters & Issues
Did you know that treasurers, auditors, and other financial officers were trusted more than 65% of the time on financial issues over their governor or member of congress?
COMMENT LETTER TO STATE STREET (Signers include 17 state officials, March 14, 2024):
State Leaders Urge State Street to Offer Investors Options That Do Not Incorporate ESG Concerns
COMMENT LETTER TO GLASS LEWIS (Signers include 18 state officials, October 24, 2023):
State Leaders Follow Up with Proxy Advisory Firm Glass Lewis for Further Clarification on how ESG Impacts Proxy Votes and Debanking
COMMENT LETTER TO ISS (Signers include 18 state officials, October 24, 2023):
State Leaders Follow Up with Proxy Advisory Firm ISS for Further Clarification on how ESG Impacts Proxy Votes and Debanking
COMMENT LETTER, UTAH INITIATED (Signers include 21 state officials, May 15, 2023):
State Leaders ask Asset Managers for Clarification on how ESG Impacts Shareholder Proposals
COMMENT LETTER, UTAH INITIATED (Signers include 22 state officials, May 15, 2023):
State Leaders ask Proxy Advisory Firms for Clarification on how ESG Impacts Proxy Votes
SFOF LETTER TO MORNINGSTAR (Signers include 18 state officials, August 25, 2022):
SFOF State Leaders Raise Concern that Wholly-Owned Subsidiary, Sustainalytics, Negatively Rates Firms Connected to Israel
KENTUCKY LETTER TO S & P GLOBAL RATINGS (Signers include state officials, June 29, 2022):
Kentucky Officials Object to S&P’s Use of ESG Criteria in State Credit Ratings
SFOF COMMENT LETTER (23 signers, June 17, 2022):
Securities and Exchange Commission – The Enhancement and Standardization of Climate-Related Disclosures for Investors (File Number S7-10-22)
VIDEO – Idaho ESG Public Education Forum (June 11, 2022):
(Hosted by Idaho Treasurer Julie Ellsworth, featuring U.S. Senator Mike Crapo, with multiple panelists)
COMMENT LETTER, UTAH INITIATED, (18 signers, June 3, 2022):
FDIC – Principles for Climate-Related Financial Risk Management for Large Financial Institutions (RIN 3064–ZA32)
COMMENT LETTER, UTAH INITIATED, (Multiple signers, 23 states represented, May 16, 2022):
Dept. of Labor – Request for Information on Possible Agency Actions to Protect Life Savings and Pensions from Threats of Climate Related Financial Risk Z–RIN 1210–ZA30
IDAHO LETTER TO S & P GLOBAL RATINGS (Signers include federal and state officials, May 18, 2022):
Idaho Officials Object to S&P’s Use of ESG Criteria in State Credit Ratings
UTAH LETTER TO S & P GLOBAL RATINGS (Signers include federal and state officials, April 21, 2022):
Utah Officials Object to S&P’s Use of ESG Criteria in State Credit Ratings
SFOF LETTER TO PRESIDENT BIDEN (23 states represented, 27 signers, April 5, 2022):
Declaration of Americas Energy Independence
COMMENT LETTER, UTAH INITIATED (24 states represented, March 8, 2022):
MSRB –Â Request for Information on Environmental, Social and Governance (ESG) Practices in the Municipal Securities Market (2021-17)
COMMENT LETTER, UTAH INITIATED (23 states represented, February 14, 2022):
Office of the Comptroller of the Currency – Risk Management: Principles for Climate-Related Financial Risk Management for Large Banks, Docket ID OCC-2021-0023, OCC Bulletin 2021-62 (December 16, 2021)
SFOF LETTER TO PRESIDENT BIDEN (21 states represented, 25 signers, January 31, 2022):
Opposition to Nominee Sarah Bloom Raskin for Federal Reserve Bank
COMMENT LETTER, UTAH INITIATED (23 states represented, December 13, 2021):
Dept. of Labor – Prudence and Loyalty in Selecting Plan Investments and Exercising Shareholder Rights (EBSA-2021-0013-0001) (RIN 1210-AC03)
LETTER, WEST VIRGINIA INITIATED, TO U.S. BANKS (16 signers, November 22, 2021):
Encouragement to Continue to do Business with American Energy
SFOF LETTER TO PRESIDENT BIDEN (18 states represented, 22 signers, November 12, 2021):
Opposition to Nominee Saule Omarova to U.S. Comptroller of the Currency
SFOF LETTER TO PRESIDENT BIDEN & TREASURY SEC YELLEN (20 states represented, 24 signers, September 20, 2021):
Opposition to U.S. Treasury Dept’s proposal to have the IRS monitor $600 transactions in bank accounts.
LETTER, WEST VIRGINIA INITIATED, TO JOHN KERRY, SPECIAL PRESIDENTIAL ENVOY FOR CLIMATE (15 signers, May 25, 2021):
Letter to John Kerry regarding fossil fuel lending
NACs
COMMENT LETTER Â (Signers include 26 state officials, January 17, 2024):
SEC Secretary Countryman – Requesting the SEC to Reject the Proposed NAC Rule.
COMMENT LETTER Â (Signers include 23 state officials, December 20, 2023):
SEC Chairman Gary Gensler – Requesting an Extension to the Public Comment Process.
Debanking
COMMENT LETTER Â (Signers include 15 state officials, April 18, 2024):
Bank of America CEO Brian Moynihan – State Leaders Raise Concern Over Bank Of America’s Track Record of Debanking Religious Groups and Conservatives
AI
COMMENT LETTER Â (Signers include 16 state officials, October 10, 2023):
SEC Chairman Gary Gensler – Expressing Concern on Burdensome Regulations on the Use of AI and Predictive Data Analytics When Making Investments.
Mortgage Rule
COMMENT LETTER, PENNSYLVANIA INITIATED (Signers include 34 state officials, May 1, 2023):
President Joseph Biden & Federal Housing Financial Authority Director Sandra Thompson – Expressing Concern & Calling for an End to the New Mortgage Rule
Debt Ceiling
COMMENT LETTER (Signers include 22 state officials, May 31, 2023):
U.S. Department of the Treasury Secretary Janet Yellen – Request for clarification on the Treasury’s Plans in the Event of Debt Ceiling Negotiations Exceeding Beyond the June 5 Deadline