Accompanying disclosure
Finally, to avoid being misleading, staff are of the view that a sales communication that includes fund-level ESG ratings, scores or rankings should include the following disclosure:
(a) the name of the provider that prepared the fund-level ESG rating, score or ranking;
(b) the date or time period covered by the fund-level ESG rating, score or ranking:
(i) if the fund-level ESG rating, score or ranking is as of a specific point in time, the date of the specific point in time;
(ii) if the fund-level ESG rating, score or ranking covers a time period:
(A) the period of time; and
(B) a brief explanation of how the fund-level ESG rating, score or ranking was determined for the specified time period (e.g. if the fund-level ESG rating, score or ranking is based on an average of the monthly fund-level ESG ratings, scores or rankings from the past 12 months);
(c) how often the fund-level ESG rating, score or ranking is updated by the provider (e.g. on a monthly basis);
(d) cautionary language stating that the fund’s ESG characteristics and performance may differ from time to time;
(e) for Portfolio-Based ESG Ratings, t he percentage of the fund’s underlying portfolio holdings that has been rated;
(f) for Portfolio-Based ESG Rankings, the percentage of the fund’s underlying portfolio holdings that has been rated for the purpose of the Portfolio-Based ESG Rating on which the Portfolio-Based ESG Ranking is based;
(g) for fund-level ESG ratings or scores, the range of the fund-level ESG rating or score (e.g. AAA to CCC);
…continues to items (h) to (q)