Subject: File No. S7-06-16
From: Katherine V Smith, 4176766

July 14, 2016

In recent years, the investment industry has developed a subcategory of socially responsible investment funds (SRIs) that assert certain material facts about the environmental and social impacts of the companies that are included in the portfolios of these SRIs.

According to the US SIF Foundations 2014 Report on Sustainable and Responsible Investing Trends in the United States, as of year-end 2013, more than one out of every six dollars under professional management in the United States—$6.57 trillion or more—was invested according to SRI strategies.

It would seem that if investment companies are being allowed to represent social and environmental performance as differentiated product attributes, there should be some oversight as to the veracity of the claims of "socially responsible" and "green" funds.

Mandatory reporting on environmental, social, and governance performance would be one way to accomplish this. The disclosure of material sustainability information strengthens competitiveness and ensures sustainable prosperity, not only for this quarter and this year, but for generations to come and ensures that investors who are selecting SRI funds are, in fact, getting what they are being sold with these SRI funds--socially and environmentally responsible companies in their portfolios.

The EU Directive 2014/95 will go into effect In December 2016. The Directive does not introduce a requirement on the reporting framework that should be used to report, however, companies are encouraged and expected to rely on one of the internationally recognized instruments such as the Global Reporting Initiative (GRI) Framework , the UNGC Principles, the UN Guiding Principles on Business and Human Rights, the OECD Guidelines for Multinational Enterprises, ISO 260009, the ILO Tripartite Declaration of principles concerning multinational enterprises and social policy and European Eco-Management and Audit Scheme (EMAS). The SEC should strive for harmonization where possible and embrace parallel guidance on reporting to encourage comparability and adoption.