Subject: S7-17-22: WebForm Comments from Allan W Moskowitz, CFP, AIF
From: Allan W Moskowitz, CFP, AIF
Affiliation: CEO Transformative Wealth Management, LLC

Jun. 10, 2022

June 10, 2022

 We are in favor of your proposal to mandate that investment companies disclose how they incorporate environmental, social and governance factors (ESG factors) into their investment process, i.e.-greenhouse gas emissions, especially if they say they advertise as ESG Mutual Funds or Exchange Traded Funds(ETF's).  We propose that the data used to verify the information be science-based targets or SBT's, since less than 20% of ESG \"mandated\" funds actually use SBT's. We believe in trust but verify with acceptable data to prove whether a company is greenwashing or not.  Thank you for allowing us to comment on this proposal and for the SEC in making this proposal. We believe you are on the  right track, as there is much greenwashing going on due to the increased demand from investors to reduce the harm being done with their money and investments and it is difficult for the public to differentiate whether what is being said is real or not.  Another suggestion might be for companies to di
 sclose how long they've used ESG factors in making investment decisions, but not cumulatively, as in our staff has over 100 years of experience in ESG investing, when they have 100 employees with only 1 year of experience, to further confuse and make it sound like they have more experience than they actually do. Some funds should also not be allowed to call themselves ESG funds if their scope of investing is limited to say exclude only tobacco or similar limited screens or objectives.