Direct Lobbying Transparency
| Overall Assessment | Comment | Score |
|---|---|---|
| Comprehensive | State Street Corporation provides a highly transparent picture of its climate-policy lobbying. It identifies several concrete rule-makings it has engaged on, including the U.S. SEC’s proposed rule “The Enhancement and Standardization of Climate-Related Disclosures for Investors (File No. S7-10-22),” the SEC proposal on “Enhanced disclosures by certain investment advisers and investment companies about environmental, social and governance investment practices (File No. S7-17-22),” and the Federal Reserve’s “Draft Principles for Climate-Related Financial Risk Management for Large Financial Institutions (Docket No. OP-1793).” The company also details its methods and targets: it submitted formal comment letters and emails directly to the U.S. Securities and Exchange Commission (addressed to Ms. Vanessa A. Countryman), provided written feedback to the Board of Governors of the Federal Reserve System, and responded to other consultations such as the ISSB exposure drafts, clearly naming each body it sought to influence. Finally, the disclosures spell out the changes it is asking for. In its SEC letter it calls for “greater flexibility with respect to Scope 3 emissions disclosures,” urges the Commission to “refrain from mandating Scope 3 emissions disclosures,” and recommends that “the Commission should allow registrants to provide any additional climate disclosures in a furnished, rather than filed, format on a comply or explain basis.” It likewise presses the Fed to adopt a “flexible approach” tailored to custody banks and asks the SEC to refine ESG fund categories, restrict GHG reporting to funds with explicit reduction targets, and sequence disclosure requirements to align with issuer data availability. By naming the policies, showing how and to whom it lobbies, and clarifying the specific regulatory outcomes it seeks, State Street demonstrates comprehensive transparency in its climate lobbying activities. | 4 |