Comment Letters & Issues

ESG Education

COMMENT LETTER TO PHARMACIES RE: NYC COMPTROLLER  (Signers include 17 state officials, September 9, 2024):
State Leaders Urge National Pharmacy Chains to Disregard NYC Comptroller’s Demand to Carry the Abortion Pill

COMMENT LETTER TO ISS  (Signers include 16 state officials, September 5, 2024):
State Leaders Call Out the Inclusion of Environmental and Social Topics in ISS’s Annual Benchmark Policy Survey and Review

COMMENT LETTER TO THE BUSINESS ROUNDTABLE  (Signers include 14 state officials, August 28, 2024):
State Leaders Call for a Reversal from The Business Roundtable after Five Years of Failure following Redefinition of The Purpose of Corporation

COMMENT LETTER TO FASB  (Signers include 26 state officials, August 12, 2024):
State Leaders Voice Concerns Over the Politicization of GAAP

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 – 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

National Debt

LETTER TO CONGRESSIONAL LEADERS  (Signers include 37 state officials, November 18, 2024):
State Financial Officers Urge Members of Congress to address the National Debt 

China

LETTER TO PUBLIC PENSION FUND FIDUCIARIES  (Signers include 20 state officials, November 1, 2024):
State Financial Officers Present Fiduciary Justifications for Public Pension Fund Divestment from China-Based Investments

DEI

LETTER TO FORTUNE 1000 EXECUTIVES  (Signers include 17 state officials, October 24, 2024):
State Financial Officers Urge Major Companies to Abandon ‘Discriminatory’ DEI Policies.

Israel

RESOLUTION IN SUPPORT OF ISRAEL  (Signers include 29 state officials, May 14, 2024):
US President Joseph R. Biden – Resolution from State Financial Officers Reaffirming Support for Israel.

LETTER TO PRESIDENT JOE BIDEN  (From SFOF National Chairs, May 14, 2024):
US President Joseph R. Biden – Letter from SFOF National Chairs.

NACs

COMMENT LETTER  (Signers include 26 state officials, January 17, 2024):
SEC Secretary Countryman – Requesting the SEC to Reject the Proposed NAC Rule.

COMMENT LETTER  (Signers include 23 state officials, December 20, 2023):
SEC Chairman Gary Gensler – Requesting an Extension to the Public Comment Process.

Debanking

COMMENT LETTER  (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  (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

State Budget & Spending

Rich States, Poor States, 15th Edition – by Jonathan Williams, Dr. Arthur B. Laffer & Stephen Moore