State financial officer stances on environmental, social, and corporate governance (ESG), 2022-2023

Environmental, social, and corporate governance


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This page tracks statements state financial officers (SFO) have made about environmental, social, and corporate governance (ESG). ESG refers to an investment or corporate governance approach that involves considering the extent to which corporations conform to certain ESG standards (such as net carbon emission or corporate board diversity goals) and making business and investment decisions that promote those standards.

In the context of public policy, ESG refers to the use of non-financial ESG investing criteria in the regulation and management of public funds, including public pensions.

Different states have different names for state financial officers, but they all fall into three groups: treasurers, auditors, and controllers. Broadly, these officials are responsible for things like auditing other government offices, managing payroll, and overseeing pensions. In some states, certain SFOs are also responsible for investing state retirement and trust funds, meaning they get to decide where that public money goes. SFOs have taken stances on ESG.

This page covers SFOs' public stances on ESG, including statements made from 2022 to 2023.

Click below to see ESG stances by state financial officers in your state. Click on an officeholder's name to learn more about his or her time in office.

Alabama

Young Boozer (Treasurer)

As of August 2023, Boozer (R) is the Alabama Treasurer. He assumed office on October 1, 2021.

Stances on ESG (click to expand)

As treasurer, Boozer took positions in opposition to environmental, social, and corporate governance (ESG), an approach to investing and corporate decision-making.
State financial officers, including treasurers, auditors, and controllers, are responsible for auditing other government offices, managing payroll, and overseeing pensions. In some states, certain SFOs are also responsible for investing state retirement and trust funds.

West Virginia letter supporting financial system access for fuel industry (November 2021)

Boozer was a co-signer on a November 22, 2021, letter sent by West Virginia State Treasurer Riley Moore and addressed: “To Whom It May Concern in the U.S. Banking Industry.” The signatories were the treasurers, auditors, and comptrollers from fifteen states. The letter identified them as the “fiduciaries and stewards of more than $600 billion” in combined investment capital.^[1]
The letter began: “We are writing to notify you that we will be taking collective action in response to the ongoing and growing economic boycott of traditional energy production industries by U.S. financial institutions.” The signatories wrote their individual actions would be tailored to fit each state’s unique laws and economic position, but that the coordinated objective would be “to select financial institutions that support a free market and are not engaged in harmful fossil fuel industry boycotts for our states’ financial services contracts.”^[2]

Arizona

Kimberly Yee (Treasurer)

As of August 2023, Kimberly Yee (R) is the Arizona Treasurer. She assumed office on January 7, 2019.

Stances on ESG (click to expand)

As treasurer, Yee took positions in opposition to environmental, social, and corporate governance (ESG), an approach to investing and corporate decision-making.

State financial officers, including treasurers, auditors, and controllers, are responsible for auditing other government offices, managing payroll, and overseeing pensions. In some states, certain SFOs are also responsible for investing state retirement and trust funds.

“As Arizona’s Chief Banking and Investment Officer, my primary responsibility is to protect and safeguard more than $53 billion of taxpayer dollars moving through our office each year,” she said in August 2022. “Since I took office in January of 2019, I have fought back against ESG policies imposed across the country.”^[3]

Letter to John Kerry regarding banking access for energy firms (May 2021)

Yee was one of fourteen other state treasurers who co-signed a May 2021 letter sent by West Virginia State Treasurer Riley Moore to Special Presidential Envoy for Climate John Kerry. The treasurers informed Kerry of their concern that he and others in President Joe Biden’s administration were “privately pressuring U.S. banks and financial institutions to refuse to lend to or invest in coal, oil, and natural gas companies, as part of a misguided strategy to eliminate the fossil fuel industry in our country.” The signatories told Kerry that they “strongly oppose the Biden Administration’s efforts to cut off financing for law-abiding industries that are essential to the economy and our citizens’ way of life.”^[4]

According to a March 12, 2021, Politico story referenced in the letter, Kerry was “prodding major U.S. banks privately to announce commitments for climate-friendly finance.” The report also revealed that the Biden administration and several climate policy groups held a March 9, 2022, teleconference to discuss “potential financial sector regulations and executive actions to limit risk from climate change-fueled shocks.” Politico listed representatives from the following groups as participants on the call: the Center for American Progress, Public Citizen, Rainforest Action Network, Sierra Club, and 350.org.^[5]^[4]

“I do not tolerate any financial institution that does not respect the best interests of Arizonans, and I will not tolerate the Biden Administration denying banking to lawful energy companies,” Yee said.^[6]

West Virginia letter supporting financial system access for fuel industry (November 2021)

Yee was also a co-signer on a November 22, 2021, letter sent by West Virginia State Treasurer Riley Moore and addressed: “To Whom It May Concern in the U.S. Banking Industry.” The signatories were the treasurers, auditors, and comptrollers from fifteen states. The letter identified them as the “fiduciaries and stewards of more than $600 billion” in combined investment capital.^[7]

The letter began: “We are writing to notify you that we will be taking collective action in response to the ongoing and growing economic boycott of traditional energy production industries by U.S. financial institutions.” The signatories wrote their individual actions would be tailored to fit each state’s unique laws and economic position, but that the coordinated objective would be “to select financial institutions that support a free market and are not engaged in harmful fossil fuel industry boycotts for our states’ financial services contracts.”^[7]

Divesting state funds from Ben & Jerry’s (September 2021)

In July 2021, American ice cream maker Ben & Jerry’s announced it was ending sales of its products in the “occupied Palestinian territory.” In response, Israeli Prime Minister Naftali Bennett said Ben & Jerry’s had become the “anti-Israel ice cream.”^[8]

Ben & Jerry’s is a subsidiary of Unilever, PLC, a publicly traded multinational consumer products conglomerate.

On August 3, 2021, Yee informed Unilever that Ben & Jerry’s was in violation of Arizona law because of its policy toward Israel. According to a news release from Yee’s office: “Arizona law (Arizona Revised Statutes §35-393 et seq.) states that public state entities may not invest moneys with an entity that boycotts Israel.”^[9]

On September 7, 2021, Yee announced the state’s $143 million investment in Unilever would be zeroed out by the end of the month because Unilever had failed to amend the policy.^[9]

“I gave Unilever PLC, the parent company of Ben & Jerry’s, an ultimatum: reverse the action of Ben & Jerry’s or divest itself of Ben & Jerry’s to come into compliance with Arizona law or face the consequences. They chose the latter,” said Yee.^[9]

Letter to Unilever CEO regarding Ben & Jerry’s anti-Israel policy (December 2021)

On December 9, 2021, six other state treasurers joined Yee as co-signers on a letter she sent to Unilever CEO Alan Jope, accusing him of attempting to “deflect responsibility for Ben & Jerry’s boycott by suggesting that you have no authority over your subsidiary’s decision in this case.” The letter cited two law professors who had reviewed the Ben & Jerry’s acquisition agreement and found that it required Ben & Jerry’s to “help Unilever sell the premium ice cream in Israel.” Yee and the other treasurers asked Jope to provide “full clarification and transparency regarding Unilever’s ability to override the discriminatory boycott of Israel initiated by Ben & Jerry’s.”^[10]

"I was proud to lead Arizona as the first state in a national effort to divest from woke company Ben & Jerry's for their anti-Semitic, discriminatory boycott of Israel, divesting $143 million in September,” Yee said, according a news release regarding the joint letter from the treasurers to Jope.^[11]

In June 2022, Unilever announced it was selling the Israeli rights to the ice cream to American Quality Products (AQP), allowing sales to resume in Israel under the new label. In a Twitter statement, Ben & Jerry’s expressed its disagreement with the policy change:

“

“While our parent company has taken this decision, we do not agree with it. Unilever’s arrangement means Ben & Jerry’s in Israel will be owned and operated by AQP. Our company will no longer profit from Ben & Jerry’s in Israel.” ^[12]^[13]

”

Opposition to U.S. Department of Labor ESG rules (December 2021)

In December 2021, Yee and 35 other state financial officers and attorneys general submitted a public comment to the U.S. Department of Labor (DOL) in opposition to a proposed DOL rule that would encourage financial managers to consider ESG factors when selecting investments for private sector pension plans.^[14]

Titled the “Prudence and Loyalty in Selecting Plan Investments and Exercising Shareholder Rights,” the rule would state that pension plan managers “can make investment decisions that reflect climate change and other environmental, social, or governance (‘ESG’) considerations, including climate-related financial risk, and choose economically targeted investments (‘ETIs’) selected, in part, for benefits apart from the investment return.”^[14]

Oaks and the other officials wrote that the rule “would allow employers and investment managers to invest employee retirement savings in a way that benefits social causes and corporate goals even if it adversely affects the return to the employee” and that it would permit “proxy voting in ways that support ESG investment goals contrary to shareholder interests.”^[14]

The state officials wrote that they were “opposed to investment managers and employers being encouraged or mandated to consider ESG factors and protected from legal action when they do” and that the DOL’s proposed rule “makes what should be a financial decision into a political one.”^[14]

Opposition to Federal Reserve Bank appointee (January 2022)

In January 2022, Yee was one of 25 members of the State Financial Officers Foundation (SFOF) who co-signed a letter to President Joe Biden (D), asking him to withdraw the nomination of Sarah Bloom Raskin to the Federal Reserve Bank Board of Governors.^[15]

In a May 2020 New York Times commentary titled “Why Is the Fed Spending So Much Money on a Dying Industry?,” Raskin wrote that Federal Reserve policy decisions should oppose investments in fossil fuels and support investments in the renewable energy sector: “The decisions the Fed makes on our behalf should build toward a stronger economy with more jobs in innovative industries — not prop up and enrich dying ones.”^[16]

Yee and the signatories on the SFOF letter wrote that they were concerned Raskin “would use the supervisory authority as Vice-Chair for Supervision at the Federal Reserve Bank to disrupt the private banking sector, reliable energy supplies, and the U.S. economy.”^[15]

In March 2022, Raskin withdrew her name from consideration for the Federal Reserve position.^[17]

Opposition to Morningstar ratings of Israel investments (August 2022)

In a letter dated August 18, 2022, Yee informed Kunal Kapoor, CEO of the ratings firm Morningstar Inc., that its subsidiary, Sustainalytics, was using “anti-Israel and antisemitic sources to negatively impact the scores of companies doing business in Israel and Israel-controlled territories.” Yee wrote that the ESG policy was not in compliance with a 2016 Arizona law that prohibited the state from doing business with individuals and corporations that engage in “actions that are intended to limit commercial relations with entities doing business in Israel.” She also informed Kapoor that the law required her office to “compile a list of restricted companies that are boycotting Israel.”

The letter gave the Morningstar CEO 30 days to provide “written certification” that the firm’s ESG policies were not violating the law and a promise not to “engage in any future boycott activities.”^[18]

On August 25, 2022, Yee and 17 other members of the State Financial Officers Foundation (SFOF) co-signed a letter addressed to Morningstar expressing their “serious concern” that Sustainalytics “negatively rates firms connected to Israel in apparent alignment with the Boycott, Divestment, Sanctions (BDS) movement.” The letter asserted the BDS movement was “antithetical to the global causes of peace, democracy, and human rights” and asked Morningstar to take corrective action immediately to terminate all research and ratings products that treat Israel-connected companies different from companies operating in other free democracies.” ^[19]

Arizona Board of Investment adopts prohibition of ESG criteria (August 2022)

On August 30, 2022, Yee and the Arizona Board of Investment approved revisions to the Arizona State Treasurer’s Office Investment Policy Statement to stipulate that “investments by or on behalf of the Treasurer” must be “based on a fiduciary standard of care and only consider pecuniary factors when evaluating an investment or discharging its duties with respect to this investment policy statement.” The new policy generally prohibits investment officers working on behalf of the state from basing their decisions on “non-pecuniary” factors, and additionally cites three specific prohibitions:

1. International, domestic, or industry agreements relating to environmental or social goals.

2. Corporate governance structures based on social characteristics.

3. Social or environmental goals.^[20]

A news release from Yee’s office stated: “Adopting this language ensures that the Arizona State Treasurer’s Office investments are not subject to the subjective political whims of the Environmental, Social and Governance (ESG) standards.”

“This is about maintaining American free-market principles that our country was founded upon and not allowing environmental or social goals to dictate how taxpayer monies are managed,” said Yee.^[21]

Arkansas

Dennis Milligan (Auditor)

As of August 2023, Dennis Milligan (R) is the Arkansas Auditor of State.

Stances on ESG (click to expand)
Milligan took positions in opposition to environmental, social, and corporate governance (ESG), an approach to investing and corporate decision-making.
State financial officers, including treasurers, auditors, and controllers, are responsible for auditing other government offices, managing payroll, and overseeing pensions. In some states, certain SFOs are also responsible for investing state retirement and trust funds.
In 2022, Milligan said, "I am proud to have been a champion fighting these policies since 2019 when I directed my investment team to remove any investments we might have from China and other countries that work to harm America. As recently as March of this year, we also pulled $125 million from BlackRock for their CEO's outspokenness against the natural energy industry."^[22]

Opposition to Morningstar ratings of Israel investments (August 2022)

In August 2022, Milligan and 17 other members of the State Financial Officers Foundation (SFOF) signed a letter addressed to Morningstar, a financial services firm, expressing their “serious concern regarding reports that Morningstar, Inc. (Morningstar), through its wholly-owned subsidiary, Sustainalytics, negatively rates firms connected to Israel in apparent alignment with the Boycott, Divestment, Sanctions (BDS) movement.” The letter said the BDS movement was “antithetical to the global causes of peace, democracy, and human rights” and asked Morningstar to take corrective action immediately to terminate all research and ratings products that treat Israel-connected companies differently than companies operating in other free democracies.”^[23]

Opposition to SEC proposal to mandate ESG reporting (June 2022)

In June 2022, Milligan and 22 other state financial officials submitted a comment to the Securities and Exchange Commission (SEC) opposing a proposed rule called “Enhancement and Standardization of Climate-Related Disclosures for Investors.” In December 2022, the Pittsburgh Business Times reported the rule “would become some of the first mandatory environmental, social and governance (ESG) reporting requirements for U.S. companies, requiring the disclosure of climate-related risk information in registration statements and periodic reports.”^[24]^[25]
The signatories said, “We have watched with dismay as the Commission and other federal commissions and boards have proposed rules and policies that promote political causes that will adversely affect public finance and retirement income. The Proposed Rule is another such rule.”^[26]

Letter to Department of Labor regarding use of ESG criteria in ERISA decisions (May 2022)

In May 2022, Milligan and 37 state officials from 23 states signed a letter to the Employment Benefits Security Administration to oppose a proposed agency rule. The proposed rule would allow fiduciaries of private pension plans governed by the Employee Retirement Income Security Act (ERISA) to “make investment decisions that reflect climate change and other environmental, social, or governance ('ESG') considerations, including climate-related financial risk, and choose economically targeted investments ('ETIs') selected, in part, for benefits apart from the investment return.”^[27]
The signatories said the rule “would irrationally require fiduciaries to elevate immaterial and speculative risks in employee retirement savings investment decisions” where instead the fiduciaries should be “considering only the material financial or pecuniary factors of each potential investment.”^[28]

Removal of state funds from BlackRock (March 2022)

As state treasurer in March 2022, Milligan announced that he was removing $125 million in Arkansas state-managed investments from the asset management firm BlackRock. A Milligan representative cited BlackRock’s reliance on ESG factors in its investment strategy as the reason for the state’s disinvestment.^[29]
Milligan's representative said, "Once we began to see BlackRock's active global political activity (handpicking companies that aligned with their ESG beliefs and beliefs we feel most Arkansans are opposed to), we began divesting and were fully divested by March 1."^[30]

Opposition to Federal Reserve Bank appointee (January 2022)

In January 2022, Milligan was one of 25 members of the State Financial Officers Foundation (SFOF) who signed a letter to President Joe Biden (D), asking him to withdraw Sarah Bloom Raskin's nomination to the Federal Reserve Bank Board of Governors.^[31]
In a May 2020 New York Times commentary titled “Why Is the Fed Spending So Much Money on a Dying Industry?,” Raskin wrote that Federal Reserve policy should prioritize investments in the renewable energy sector: “The decisions the Fed makes on our behalf should build toward a stronger economy with more jobs in innovative industries — not prop up and enrich dying ones.”^[32]
Milligan and the signatories on the SFOF letter wrote that they were concerned Raskin “would use the supervisory authority as Vice-Chair for Supervision at the Federal Reserve Bank to disrupt the private banking sector, reliable energy supplies, and the U.S. economy.”^[31]
In a separate news release, Milligan said, “This liberal idea that banks should move away from funding organizations that invest in reliable energy sources is partisan and has no place in the free market."^[33]
In March 2022, Raskin withdrew her name from consideration for the Federal Reserve position. ^[34]

Opposition to U.S. Department of Labor ESG rules (December 2021)

In December 2021, Milligan and 35 other state financial officers and attorneys general submitted a public comment to the U.S. Department of Labor (DOL) in opposition to a proposed DOL rule. The rule would encourage financial managers to consider ESG factors when selecting investments for private sector pension plans.^[35]
Titled the “Prudence and Loyalty in Selecting Plan Investments and Exercising Shareholder Rights,” the rule said pension plan managers “can make investment decisions that reflect climate change and other environmental, social, or governance (‘ESG’) considerations, including climate-related financial risk, and choose economically targeted investments (‘ETIs’) selected, in part, for benefits apart from the investment return.”^[35]
Milligan and the other officials wrote the rule “would allow employers and investment managers to invest employee retirement savings in a way that benefits social causes and corporate goals even if it adversely affects the return to the employee,” and that it would permit “proxy voting in ways that support ESG investment goals contrary to shareholder interests.”^[36]
Milligan and the other officials said they were “opposed to investment managers and employers being encouraged or mandated to consider ESG factors and protected from legal action when they do” and that the DOL’s proposed rule “makes what should be a financial decision into a political one.”^[36]

West Virginia letter supporting financial system access for fuel industry (November 2021)

Milligan, along with treasurers, auditors, and comptrollers in 15 states, signed West Virginia State Treasurer Riley Moore's (R) November 22, 2021, letter to the U.S. banking industry.^[37]
The letter said: “We are writing to notify you that we will be taking collective action in response to the ongoing and growing economic boycott of traditional energy production industries by U.S. financial institutions.”^[37] The signatories said their objective was to "select financial institutions that support a free market and are not engaged in harmful fossil fuel industry boycotts for our states’ financial services contracts."^[37]

Letter to John Kerry regarding banking access for energy firms (May 2021)

Milligan was one of 14 state financial officials who signed West Virginia State Treasurer Riley Moore's (R) May 2021 letter to Special Presidential Envoy for Climate John Kerry. The treasurers said Kerry and others in Joe Biden’s administration were “privately pressuring U.S. banks and financial institutions to refuse to lend to or invest in coal, oil, and natural gas companies, as part of a misguided strategy to eliminate the fossil fuel industry in our country.” The signatories said they “strongly oppose the Biden Administration’s efforts to cut off financing for law-abiding industries that are essential to the economy and our citizens’ way of life.”^[38]
According to Politico's Zach Colman, Kerry was “prodding major U.S. banks privately to announce commitments for climate-friendly finance.” Colman reported the Biden administration and several climate policy groups held a March 9, 2022, teleconference to discuss “potential financial sector regulations and executive actions to limit risk from climate change-fueled shocks.” Colman reported representatives from the following groups as participants on the call: the Center for American Progress, Public Citizen, Rainforest Action Network, Sierra Club, and 350.org.^[39]^[40]
The United States Department of State denied Kerry pressured institutions on environmental subjects.^[41]

Mark Lowery (Treasurer)

As of August 2023, Mark Lowery (R) was the Arkansas Treasurer.

Stances on ESG (click to expand)
Lowery took positions opposing environmental, social, and corporate governance (ESG), an approach to investing and corporate decision-making.
State financial officers, including treasurers, auditors, and controllers, are responsible for auditing other government offices, managing payroll, and overseeing pensions. In some states, certain SFOs are also responsible for investing state retirement and trust funds.
Lowery said, “We have to be careful to not invest in this ESG. I don’t know if you are familiar with it, but you can only invest in companies that are environmentally, socially, or globally competent. We need to invest in companies that are making the best return for the state of Arkansas. I pledge to you that I will do that.”^[42]

Removal of state funds from BlackRock (March 2022)

In March 2022, Arkansas State Treasurer Dennis Milligan (R) announced he was removing $125 million in Arkansas state-managed investments from BlackRock, an asset management firm. A representative for Milligan cited BlackRock’s reliance on ESG factors in its investment strategy as the reason for the state’s disinvestment.^[43]
Lowery endorsed Milligan’s decision, saying: “I congratulate Treasurer Dennis Milligan in disinvesting Arkansas from any BlackRock investments after revelation of their ties to the Communist Chinese military."^[44]

California

Malia Cohen (Controller)

Malia Cohen (D) is the California Controller. She assumed office on January 2, 2023.

Stances on ESG (click to expand)

Cohen took positions supporting the environmental, social, and corporate governance (ESG), an approach to investing and corporate decision-making.

State financial officers, including treasurers, auditors, and controllers, are responsible for auditing other government offices, managing payroll, and overseeing pensions. In some states, certain SFOs are also responsible for investing state retirement and trust funds.

ESG Proposals as Candidate for State Controller (2022)

As a candidate for state controller in 2022, Cohen released a four page economic plan. The document outlined several ESG-related proposals:^[45]

“

California’s Controller occupies a critical role in building a climate action agenda for our state. As a permanent member of the State Lands Commission and Chair in even numbered years, our Controller helps oversee our land, our water and the rights to the natural resources of our state.

Overseeing land management, offshore drilling and mineral rights, the State Lands Commission has a tremendous opportunity to set the strongest possible standards of conservation. As Controller, I’m committed to working toward using our public lands for renewable energy, ending our dependence on oil and gas. I will work hand-in-hand to hold current lease holders to the highest possible standards of environmental stewardship and seek opportunities to transition away from extraction policy.

The Controller’s audit function and role as a member of the California Public Employees’ Retirement System (CalPERS) and California State Teachers’ Retirement System (CalSTRS) Boards grant additional opportunities to write a greener future for our state. I will use the audit function to ensure that grant programs and spending through programs, like those awarded through the California Energy Commission, meet their end goal of advancing “the state’s transition to clean energy and transportation through innovation, efficiency, and the development and deployment of advanced technologies.” And, while California has led in leveraging our combined $570 billion public pension portfolios (the two largest pension systems in the nation) for the greater good, I’ll work to push the net-zero emissions target for the Climate Action 100 companies to 2040 – because our future can’t wait.^[13]

”

—Malia Cohen

San Francisco Employee Retirement System Fossil Fuel Divestment (2018)

In August 2017, Cohen, then a San Francisco city supervisor and member of the San Francisco City & County Employees' Retirement System, supported a measure that would have divested the county's $23 billion pension fund from fossil fuel energy firms. The fund's staff and its general investment consultant recommended against the measure. In January 2018, the board approved a modified proposal to hire a director to oversee ESG investing and divest from what the board said was the “worst of the worst” fossil fuel energy firms. Cohen supported the modified measure.^[47]^[48]

Cohen said the board had “taken another step forward to divesting of the riskiest and dirtiest fossil fuel companies.”^[49]

Fiona Ma (Treasurer)

Fiona Ma (D) is the California Treasurer. She assumed office on January 7, 2019.

Stances on ESG (click to expand)

As treasurer, Ma took stances supportive of environmental, social, and corporate governance (ESG), an approach to investing and corporate decision-making.

State financial officers, including treasurers, auditors, and controllers, are responsible for auditing other government offices, managing payroll, and overseeing pensions. In some states, certain SFOs are also responsible for investing state retirement and trust funds.

Pro-ESG financial officers’ letter opposing anti-ESG state officers (September 2022)

In September 2022, Ma and 13 other state and local financial officers signed a letter opposing laws and policies in West Virginia, Idaho, Oklahoma, Texas, and Florida "aiming to curb consideration of environmental, social and governance (ESG) factors in investing."^[50]

The letter said those states were "blacklisting financial firms that don’t agree with their political views." The letter also said, “the blacklisting states apparently believe, despite ample evidence and scientific consensus to the contrary, that poor working conditions, unfair compensation, discrimination and harassment, and even poor governance practices do not represent material threats to the companies in which they invest. They refuse to acknowledge, in the face of sweltering heat, floods, tornadoes, snowstorms and other extreme weather, that climate change is real and is a true business threat to all of us.”^[50]

Support for Stanford University ESG bonds (May 2021)

In May 2021, Ma praised Stanford University's ESG-focused bonds. The private California university claimed it was “first U.S. college or university to issue bonds carrying dual climate and sustainability designations for financing campus construction and renovation projects.”^[51]

Ma said, “ESG financing provides the multi-pronged benefits of greenhouse emission reductions, health equity research, affordable housing, and systemic and academic equity. I hope more California colleges will follow Stanford’s lead.”^[52] Ma also said, "Consumers are willing to pay more for organic products. Similarly, we believe that certain investors are willing to pay more for green investments.^[53]

Membership in Vatican Council for Inclusive Capitalism (December 2020)

In December 2020, Ma became a member of the Vatican Council for Inclusive Capitalism, a partnership between Pope Francis, major corporations, investment officers, public officials, labor unions and other ESG advocates. In January 2021, the group announced its support for clearer standards of ESG reporting, a goal Ma supported.^[54]

Ma said, “We need more and better information and we need it now. During the pandemic income and wealth disparities have increased economic injustices to near crisis levels around the world. New standards will help us judge how companies are progressing in their efforts to reduce poverty, combat climate change, and bring about fair and inclusive governance. They also put companies on notice that symbolic actions aren’t enough. They need to make real change.”^[55]

Support for ESG nonprofit’s roadmap for California (September 2020)

In September 2020, Ma endorsed the Principles for Responsible Investment's (PRI) proposal titled “The California Responsible Investment Roadmap." In a news release, PRI promoted the proposal as a “set of guidelines outlining how California investors and policymakers can advance the incorporation of Environmental, Social and Governance (ESG) considerations into investment decisions that impact the state’s economy, especially with regard to climate change.”^[56]

Ma said, “The Roadmap shows all of us the pathway to an envisioned future that seizes the initiative on climate-related finance. A thoughtful review of the Roadmap will reinforce prudent stewardship in investment decision-making and policy implementation. It is an important statement of why California’s climate strategies are so important to all of us.”^[57]

Opposition to U.S. Labor Department anti-ESG rule proposal (July 2020)

In July 2020, Ma opposed a U.S. Department of Labor rule proposal to require retirement fund managers to “select investments and investment courses of action based solely on financial considerations relevant to the risk-adjusted economic value of a particular investment or investment course of action.” The proposal, titled “Financial Factors in Selecting Plan Investments,” specifically singled out and discussed the use of ESG factors as potential violations of the requirement.^[58]^[59]

Ceres, an ESG advocacy nonprofit, opposed the proposed rule change and issued a news release on June 30, 2022, titled “Major investors oppose proposed rule that would impede ESG investing.”^[60]

“	The proposed rule would place a significant burden on fiduciaries who offer ESG funds as options in their retirement fund and could also affect the broader pension fund market by setting an unwelcome precedent that runs counter to the mainstream U.S. and global practice of integrating ESG factors into investment decisions. The DOL proposes these restrictions at a time when ESG investing is rapidly growing and more fully embraced by mainstream global finance and investment organizations^[13]	”
—Ceres^[61]

Ma said, “The evidence is clear—and building daily—that the effects of a changing climate may pose financial risks to our infrastructure, both public and private. What is missing is the full-throated acknowledgment that such risks must be institutionalized in our investment policies and decisions. The proposed rulemaking leads backward on this front, not forward.”^[62]

The Labor Department's final rule, issued in October 2020, excluded specific references to ESG factors.^[63]

In November 2022, the Department of Labor, under the administration of President Joe Biden (D), released a final rule in a proposal titled “Prudence and Loyalty in Selecting Plan Investments and Exercising Shareholder Rights.” The new rule specifically permitted employee retirement plan managers to use ESG factors when judging the value of investments, replacing rulemaking crafted under the administration of President Donald Trump (R).^[64]

Support for divesting teacher retirement fund from fossil fuel investments (September 2019)

In September 2019, as state treasurer and a board member of the California State Teachers' Retirement System (CalSTRS), Ma supported a proposal to divest CalSTRS from investments in fossil fuel energy firms. The proposal was made to a CalSTRS board meeting during the late summer of 2019 by a group of teachers and schoolchildren.^[65]

Ma said, "Where we invest our money reflects our values, and we should be valuing a clean energy future for California. These brave and passionate students are reminding us of that.”^[66]

Creation of state-run ESG-focused retirement savings plan (January 2019)

As state treasurer in January 2019, Ma announced the creation of an ESG-focused retirement savings vehicle for CalSavers, a state government-run retirement fund for private employers. According to a news release from Ma: “Under California state law, any employer with at least five employees that doesn’t already offer a workplace retirement savings vehicle is required to offer one either through the private market or by providing employees with access to CalSavers.” The release from the state treasurer also claimed the ESG investment option for private workers was the first ever offered by a state government.^[67]

Ma said, “California workers now have even more reason to open a CalSavers account and feel good about investing in their futures. They can now choose to put their retirement savings into investments that protect the environment and champion a more fair and just world.”^[68]

Colorado

Dave Young (Treasurer)

Dave Young (Democratic Party) is the Colorado Treasurer. He assumed office on January 8, 2019. His current term ends on January 12, 2027.

Young (Democratic Party) is running for election to the U.S. House to represent Colorado's 8th Congressional District. He declared candidacy for the Democratic primary scheduled on June 30, 2026.^[source]

Stances on ESG (click to expand)
As treasurer, Young took stances supporting the environmental, social, and corporate governance (ESG), an approach to investing and corporate decision-making.
State financial officers, including treasurers, auditors, and controllers, are responsible for auditing other government offices, managing payroll, and overseeing pensions. In some states, certain SFOs are also responsible for investing state retirement and trust funds.

Pro-ESG financial officers’ letter opposing anti-ESG state officers (September 2022)

In September 2022, Young and 13 other state and local financial officers signed a letter opposing laws and policies in West Virginia, Idaho, Oklahoma, Texas, and Florida "aiming to curb consideration of environmental, social and governance (ESG) factors in investing."^[50]
The letter said those states were "blacklisting financial firms that don’t agree with their political views." The letter also said “the blacklisting states apparently believe, despite ample evidence and scientific consensus to the contrary, that poor working conditions, unfair compensation, discrimination and harassment, and even poor governance practices do not represent material threats to the companies in which they invest. They refuse to acknowledge, in the face of sweltering heat, floods, tornadoes, snowstorms and other extreme weather, that climate change is real and is a true business threat to all of us.”^[50]
Young said, “I believe in the science of climate change. Everybody needs energy. I think it’s a bad fiduciary decision to actually divest from fossil fuels or only invest in fossil fuels. We need to be actually investing in businesses that have a sustainable future in mind. We’re not day traders at PERA. We’re long-term investors.”^[69]

Connecticut

Sean Scanlon (Comptroller)

As of August 2023, Sean Scanlon (D) is the Connecticut Comptroller. He assumed office on January 4, 2023.

Stances on ESG (click to expand)
Scanlon expressed support for environmental, social, and corporate governance (ESG), an approach to investing and corporate decision-making.
State financial officers, including treasurers, auditors, and controllers, are responsible for auditing other government offices, managing payroll, and overseeing pensions. In some states, certain state financial officers are also responsible for investing state retirement and trust funds.
Scanlon's 2022 campaign website included this statement: “Sean supports Connecticut's ambitious goal of reducing carbon emissions by achieving a carbon-free power grid by 2040, investing in alternative energy sources like water and wind, strengthening our shoreline through prolonged planning and resiliency measures and finding sustainable solutions like reducing our reliance on single-use plastics.”^[70]

Erick Russell (Treasurer)

Erick Russell (D) is the Connecticut Treasurer. He assumed office on January 4, 2023.

Stances on ESG (click to expand)
Russell took stances supporting environmental, social, and corporate governance (ESG), an approach to investing and corporate decision-making.
State financial officers, including treasurers, auditors, and controllers, are responsible for auditing other government offices, managing payroll, and overseeing pensions. In some states, these financial officers are also responsible for investing state retirement and trust funds.

Pro-ESG statements during state treasurer campaign (2022)

Russell’s 2022 campaign website said: “The Treasurer is also responsible for promoting strong corporate governance practices, ensuring the State’s investments reflect our values, and enhancing the financial integrity of the State. As a large shareholder, the Treasurer sits on boards of companies with whom we do business and can leverage the State’s investments to help promote socially responsible corporate governance and diversity.”^[71]
Russell's campaign site listed six specific areas of ESG policy focus: “Divesting from gun manufacturers,” “Developing a comprehensive plan for moving away from fossil fuels,” “Corporate Diversity,” “Encouraging responsible environmental practices,” “Promoting fair labor practices,” and “Advocating against excessive executive compensation.”^[72]

Delaware

Colleen Davis (Treasurer)

Colleen Davis (D) is the Delaware Treasurer. She assumed office on January 1, 2019.

Stances on ESG (click to expand)

Florida

Jimmy Patronis (Chief Financial Officer)

Jimmy Patronis (R) is the Florida Chief Financial Officer. He assumed office in 2017.

Stances on ESG (click to expand)

Patronis took positions in opposition to environmental, social, and corporate governance (ESG), an approach to investing and corporate decision-making.

State financial officers, including treasurers, auditors, and controllers, are responsible for auditing other government offices, managing payroll, and overseeing pensions. In some states, these financial officers are also responsible for investing state retirement and trust funds.

Patronis' office released, in late December 2022, a news release regarding the state CFO’s 2022 accomplishments. The release said: “CFO Patronis made it a top priority to combat Environmental, Social, and Governance (ESG) standards when investing taxpayer dollars. For years now, ESG economic activists have worked to infuse unwanted, woke ideology into the American economic system because they know their social policies wouldn’t pass voters. It’s anti-American, anti-freedom, a deliberate attempt to subvert democracy, and not in the best interest of Florida businesses, retirees, or investors.”^[73]

Divestment from Blackrock (December 2022)

In December 2022, Petronis announced “that the Florida Treasury will begin divesting $2 billion worth of assets" from the BlackRock asset management firm.^[74]

Patronis said, “Whether stakeholder capitalism, or ESG standards, are being pushed by BlackRock for ideological reasons, or to develop social credit ratings, the effect is to avoid dealing with the messiness of democracy. I think it’s undemocratic of major asset managers to use their power to influence societal outcomes. If Larry, or his friends on Wall Street, want to change the world – run for office. Start a non-profit. Donate to the causes you care about.”^[75]

The news release said the state would terminate from BlackRock's management all short and long-term investments under the Florida state treasury’s supervision by the start of 2023.^[76]

In 2022, Blackrock CEO Larry Fink wrote:

“	Stakeholder capitalism is all about delivering long-term, durable returns for shareholders. And transparency around your company’s planning for a net zero world is an important element of that. But it’s just one of many disclosures we and other investors ask companies to make. As stewards of our clients’ capital, we ask businesses to demonstrate how they’re going to deliver on their responsibility to shareholders, including through sound environmental, social, and governance practices and policies.”^[13]	”
—Larrry Fink^[77]

Opposition to Morningstar ratings of Israel investments (August 2022)

In late August 2022, Patronis and 17 other members of the State Financial Officers Foundation (SFOF) signed a letter addressed to the Morningstar investment rating service expressing their “serious concern regarding reports that Morningstar, Inc. (Morningstar), through its wholly-owned subsidiary, Sustainalytics, negatively rates firms connected to Israel in apparent alignment with the Boycott, Divestment, Sanctions (BDS) movement.” The letter asserted the BDS movement was “antithetical to the global causes of peace, democracy, and human rights” and asked Morningstar to take corrective action immediately to terminate all research and ratings products that treat Israel-connected companies differently than companies operating in other free democracies.” ^[78]

Opposition to Federal Reserve Bank appointee (January 2022)

In January 2022, Patronis was one of 25 members of the State Financial Officers Foundation (SFOF) who co-signed a letter to President Joe Biden (D), asking him to withdraw the nomination of Sarah Bloom Raskin to the Federal Reserve Bank Board of Governors.^[79]

In a May 2020 New York Times commentary titled “Why Is the Fed Spending So Much Money on a Dying Industry?,” Raskin wrote that Federal Reserve policy decisions should support investments in the renewable energy sector: “The decisions the Fed makes on our behalf should build toward a stronger economy with more jobs in innovative industries — not prop up and enrich dying ones.”^[80]

The SFOF said that they were concerned Raskin “would use the supervisory authority as Vice-Chair for Supervision at the Federal Reserve Bank to disrupt the private banking sector, reliable energy supplies, and the U.S. economy.”^[79]

In March 2022, Raskin withdrew her name from consideration for the Federal Reserve position.^[81]

Responses to Ben & Jerry’s anti-Israel policy (July 2021)

In July 2021, American ice cream maker Ben & Jerry’s announced it was ending sales of its products in what it described as the “occupied Palestinian territory.” In response, Israeli Prime Minister Naftali Bennett said Ben & Jerry’s had become the “anti-Israel ice cream.”^[82]

Ben & Jerry’s is a subsidiary of Unilever, PLC, a publicly traded multinational consumer products conglomerate.

Three days later, on July 22, 2021, Patronis sent a letter to the CEO of Ben & Jerry’s, informing the firm that “Florida law prohibits the state from investing in companies that discriminate against Israel by refusing to deal with or terminate business activities in a discriminatory matter.”^[83]

Patronis said, “With this notice, I am requesting Ben & Jerry’s share its plans to 'remain in Israel through a different arrangement' as noted in the July 19 announcement. If my office does not receive a response, I will exercise my authority by working with Florida’s SBA to place Ben & Jerry’s on the Scrutinized Companies that Boycott Israel List.”^[84]

In June 2022, Unilever announced it was selling the Israeli rights to the ice cream to American Quality Products (AQP), allowing sales to resume in Israel under the new label. In a Twitter statement, Ben & Jerry’s expressed its disagreement with the policy change: “While our parent company has taken this decision, we do not agree with it. Unilever’s arrangement means Ben & Jerry’s in Israel will be owned and operated by AQP. Our company will no longer profit from Ben & Jerry’s in Israel.”^[85]

Opposition to cancel culture in the banking industry (March 2021)

In a March 2021 letter to Florida Office of Financial Regulation Commissioner Russell Weigel, Patronis asked Weigel to “analyze whether a Florida-chartered bank that exhibits political discrimination toward a specific industry group is engaged in an 'unsound banking practice' that merits issuance of a cease and desist order” under Florida law.^[86]

Patronis wrote, “In recent months, large financial institutions have refused to extend financing and other services to entities such as firearm manufacturers, energy companies and others deemed 'too conservative' or otherwise not aligned with the 'woke left' vision of society. In short, 'cancel culture' has reached our financial markets and the result—arbitrary selection of winners and losers—is bad news for our capitalist system.”^[87]

Georgia

Steve McCoy (Treasurer)

Steve McCoy is the treasurer of Georgia. Gov. Brian Kemp (R) appointed him on June 7, 2020, and the State Depository Board approved Kemp's appointment on August 5, 2020.^[88]

Stances on ESG (click to expand)
McCoy took positions in opposition to the Environmental, social, and corporate governance (ESG) movement.
State financial officers, including treasurers, auditors, and controllers, are responsible for auditing other government offices, managing payroll, and overseeing pensions. In some states, certain SFOs are also responsible for investing state retirement and trust funds.

Pro-American Energy Letter to President Biden (April 2022)

In April 2022, McCoy and 26 other state financial officers signed an open letter to President Joe Biden (D) criticizing his administration for promoting an ESG agenda and enacting policies that “thwart the vitality of American energy production.”^[89] The letter said Biden had cancelled the Keystone XL pipeline, disallowed new oil and natural gas leases on federal lands, stopped drilling projects in Alaska, and imposed “anti-oil and gas rulemaking from the highest levels of government.”^[89]
The letter said: “Instead of asking Americans to purchase electric vehicles—which is simply not an option for a great number of American families—government leaders should eliminate barriers to and expand development of these critical resources, bringing down the price of gas at the pump. Most Americans cannot afford to purchase an electric vehicle or equip their home with a full set of solar panels, and many in rural America need traditional fuel to run the trucks that service their farms and help feed their communities.”^[90]

Letter regarding Municipal Securities Rulemaking Board ESG rules (March 2022)

In March 2022, McCoy and 22 other state financial officers signed an open letter to the Municipal Securities Rulemaking Board (MSRB) objecting to the board’s decision to issue a “Request for Information on Environmental, Social and Governance (ESG) Practices in the Municipal Securities Market.” In December 2021, the MSRB sent a letter to participants in the municipal securities market, questioning the recipients about their use of ESG criteria and their opinions regarding the propriety of using ESG criteria.^[91]^[92]
The letter said: “The seemingly innocuous RFI questions are actually precursors to MSRB rules that would require municipalities to make ESG-related disclosures." The 23 state financial officers said the MSRB was seeking “information that is useful for one purpose and one purpose alone: transgressing Congress’s ban on requiring disclosures from municipal issuers or regulating their content.”^[93]

Idaho

Brandon Woolf (Controller)

As of August 2023, Brandon Woolf (R) is the Idaho Controller. He assumed office on October 15, 2012.

Stances on ESG (click to expand)
As controller Woolf took positions in opposition to the environmental, social, and corporate governance (ESG) movement.

Letter regarding use of ESG criteria by S&P Global Ratings ( May 2022)

On May 18, 2022, Woolf co-signed a letter on behalf of the State of Idaho to the leadership of S&P Global Ratings, opposing the firm’s policy of publishing “ESG credit indicators as part of its credit ratings for states and state subdivisions.” The letter was also signed by Idaho Gov. Brad Little (R), the leadership of both the Idaho House and Senate, and the entire Utah Congressional delegation. ^[94]
The letter stated that “S&P has adopted a politicized ratings system” and as an example said that “S&P bequeathed higher ESG ratings on Russian and Chinese energy companies than on American ones.” ^[94]

Illinois

Mike Frerichs (Treasurer)

As of August 2023, Mike Frerichs (D) is the Illinois Treasurer. He assumed office on January 12, 2015.

Stances on ESG (click to expand)

As treasurer, Frerichs took positions in support of environmental, social, and corporate governance (ESG), an approach to investing and corporate decision-making.

State financial officers, including treasurers, auditors, and controllers, are responsible for auditing other government offices, managing payroll, and overseeing pensions. In some states, these financial officers are also responsible for investing state retirement and trust funds.

Pro-ESG financial officers’ letter opposing anti-ESG state officers (September 2022)

In September 2022, Frerichs and 13 other state and local financial officers signed a letter opposing laws and policies in West Virginia, Idaho, Oklahoma, Texas, and Florida "aiming to curb consideration of environmental, social and governance (ESG) factors in investing."^[50]

The letter said those states were "blacklisting financial firms that don’t agree with their political views." The letter also said, “the blacklisting states apparently believe, despite ample evidence and scientific consensus to the contrary, that poor working conditions, unfair compensation, discrimination and harassment, and even poor governance practices do not represent material threats to the companies in which they invest. They refuse to acknowledge, in the face of sweltering heat, floods, tornadoes, snowstorms and other extreme weather, that climate change is real and is a true business threat to all of us.”^[50]

Opposition to U.S. Labor Department anti-ESG rule proposal (July 2020)

In July 2020, Frerichs opposed a U.S. Department of Labor rule proposal to require retirement fund managers to “select investments and investment courses of action based solely on financial considerations relevant to the risk-adjusted economic value of a particular investment or investment course of action.” The proposal, titled “Financial Factors in Selecting Plan Investments,” specifically singled out and discussed the use of ESG factors as potential violations of the requirement.^[95]^[96]

Ceres, an ESG advocacy nonprofit, opposed the proposed rule change and issued a news release on June 30, 2022, titled “Major investors oppose proposed rule that would impede ESG investing.”^[97]

“	The proposed rule would place a significant burden on fiduciaries who offer ESG funds as options in their retirement fund and could also affect the broader pension fund market by setting an unwelcome precedent that runs counter to the mainstream U.S. and global practice of integrating ESG factors into investment decisions. The DOL proposes these restrictions at a time when ESG investing is rapidly growing and more fully embraced by mainstream global finance and investment organizations^[13]	”
—Ceres^[98]

The Labor Department's final rule, issued in October 2020, excluded specific references to ESG factors.^[99]

In November 2022, the Department of Labor, under the administration of President Joe Biden (D), released a final rule in a proposal titled “Prudence and Loyalty in Selecting Plan Investments and Exercising Shareholder Rights.” The new rule specifically permitted employee retirement plan managers to use ESG factors when judging the value of investments, replacing rulemaking crafted under the administration of President Donald Trump (R).^[100]

Russell 3000 Board Diversity Disclosure Initiative (October 2020)

In October 2020, Frerichs became the chair of the Russell 3000 Board Diversity Disclosure Initiative. The proposal, supported by 25 other public and private fund managers, asked the leadership of firms listed on the Russell 3000 stock index to disclose the racial, ethnic and gender data for the membership of their corporate boards.^[101] ^[102]

Frerichs said, “Insular corporate boards make too many decisions in an echo chamber and miss opportunities for growth and leadership. Providing racial, ethnic and gender disclosure will allow institutional investors to identify strategic weaknesses that inhibit growth and provide specific guidance to maximize shareholder value.”^[103]

In a November 2022 news release, Frerichs said the program had grown from 292 firms providing diversity disclosure in 2020 to more than 2,200 in 2022.^[104]

Frerichs said, “We are very pleased to see the majority of companies responding to our feedback and openly disclosing the diversity of their board directors. While there are many outlier companies that fail to disclose, I am optimistic about the overall trend, and more importantly, it is great to see more companies recognizing that board diversity is an area that warrants more attention and can drive performance.”^[105]

Support for Southern Company net-zero plan (May 2020)

In May 2020, Southern Company, an electric utility company, announced at its annual shareholders meeting a commitment to operate at net-zero carbon emissions by 2050. The decision was influenced by a coalition of its shareholders working in partnership with Ceres and Majority Action, a pair of ESG advocacy nonprofits. The Illinois Treasurer’s office, under the leadership of Frerichs as administrator of the state’s employee pension and other funds, was part of the coalition.^[106]

Frerichs said, “Climate change presents serious risks – and opportunities – to companies and investors. To thrive in the face of such a transformative, systemic threat such as climate change, it is critical that companies set goals, build plans and marshal the resources necessary to ensure long-term sustainability. Southern’s commitment to net-zero is an important milestone for the company and the industry – and it affirms the value of engagement between shareholders and companies, as our investor group, with the support of Ceres and Majority Action, has led a constructive dialogue with the company. Southern’s goal of net-zero carbon emissions by 2050 is a step in the right direction, and I look forward to future discussions on the company’s efforts to realize this objective.”^[107]

SEC petition seeking mandatory ESG reporting from public firms (October 2018)

In October 2018, Frerichs signed a petition to the Securities and Exchange Commission (SEC) requesting that the federal regulatory agency impose “rulemaking to develop mandatory rules for public companies to disclose high-quality, comparable, decision-useful environmental, social, and governance information.”

The letter acknowledged that “most of America’s largest public companies” were already “attempting to provide additional information” on ESG issues. But the signatories also said there were “substantial problems with the nature, timing, and extent of these voluntary disclosures,” and “problems with the quality of voluntary ESG disclosure.”^[108]

Prof. Cynthia A Williams of the Osgoode Hall Law School and Prof. Jill E Fisch of the University of Pennsylvania Law School wrote the petition. Signatories included public and private investment officials claiming to represent $5 trillion in assets under management.^[109]

Indiana

Daniel Elliott (Treasurer)

As of August 2023, Daniel Elliott (R) is the Indiana Treasurer. He assumed office on January 1, 2023.

Stances on ESG (click to expand)
Elliott took positions in opposition to environmental, social, and corporate governance (ESG), an approach to investing and corporate decision-making.
State financial officers, including treasurers, auditors, and controllers, are responsible for auditing other government offices, managing payroll, and overseeing pensions. In some states, these financial officers are also responsible for investing state retirement and trust funds.
Elliott said, “investing in ESG funds carries enhanced risks to Indiana pension funds. They are not a good idea for our public employee retirement funds. I will focus on managing pension plans based on the best interest of pension beneficiaries. Picking funds based on ESG ratings is not in the best fiduciary interest of our pensioners.”^[110]

Iowa

Roby Smith (Treasurer)

As of August 2023, Roby Smith (R) is the Iowa Treasurer of State. He assumed office on January 1, 2023.

Stances on ESG (click to expand)
Smith took positions in opposition to environmental, social, and corporate governance (ESG), an approach to investing and corporate decision-making.
During his 2022 campaign for treasurer, Smith’s website stated that “Smith strongly opposes this BDS agenda and, as Treasurer, will reject any calls to break off economic ties between the state of Iowa and the people of Israel.” The website said, “The radical BSD (boycott/sanctions/divestment) movement is a hateful, anti-Semitic plan to pressure companies, governments, and other public entities to break all economic states with Israel.”^[111]
State financial officers, including treasurers, auditors, and controllers, are responsible for auditing other government offices, managing payroll, and overseeing pensions. In some states, these financial officers are also responsible for investing state retirement and trust funds.
Asked about this position regarding state business with BlackRock, the pro-ESG asset management firm, Smith replied that he would defer to state lawmakers to set investment policy.^[112]
Smith said, "I think when it comes to investing, the number one thing is return on the money. And then number two is to make sure that we're protecting Iowa's business and industry. We don't want to invest with someone that wants to harm agriculture ... so I think the answer is we're going to wait for the legislature to give us a directive on that.”^[113]

Support for Russian divestment (March 2022)

As a state senator in March 2022, Smith advocated for the state to withdraw from investments connected to Russia.^[114]
Smith said, “In light of Vladimir Putin’s abhorrent and completely unprovoked attack on the sovereign nation of Ukraine, the State of Iowa needs to strategically divest of any Russian securities it may hold and prevent any future investment with Iowa’s public funds."^[115]

Kansas

Steven C. Johnson (Treasurer)

As of August 2023, Mike Harmon (R) is the Kentucky Auditor of Public Accounts. He assumed office in 2016.

Stances on ESG (click to expand)
Johnson took stances opposing environmental, social, and corporate governance (ESG), an approach to investing and corporate decision-making.
State financial officers, including treasurers, auditors, and controllers, are responsible for auditing other government offices, managing payroll, and overseeing pensions. In some states, these financial officers are also responsible for investing state retirement and trust funds.

Opposition to BlackRock-controlled investments (January 2023)

In January 2023, The Sentinel's Patrick Richardson said, “Kansas State Treasurer Steven C. Johnson is taking a hard look at whether ESG (Environmental, Social, and Governance) policy influences pension fund investment — and who is managing the investments.”^[116]
Johnson said he was working to prevent BlackRock, the pro-ESG asset management firm, from affecting state investments.^[117]
Johnson said, “The good news if you will, our domestic equity portfolio is entirely indexed or passive. So regardless, there are no active decisions being made on those ESG companies, And the international portfolio is actively managed and that one will take some more work to get through to see where those selection issues could be affecting us. But out of the gate, we don’t have any Blackrock actively managed funds that would be making those ESG decisions.”^[118]
Johnson also said he was also concerned with how BlackRock’s proxy voting affected state investments: “Step two is critical, and that is getting a handle on how Blackrock is voting those proxy shares. That is one of the things we will be going over, and I will ask questions to make sure that they understand how those are voted. How are those proxy shares voted? How do we continue to do it efficiently? And how do we make sure that we are not promoting an ESG agenda through Kansas assets? We need to promote an agenda for the highest and best return of assets.”^[119]^[120]

Election campaign statements (July 2022)

As a candidate for state treasurer in 2022, Johnson said a major goal of the office should be “addressing Environmental/Social/Governance issues in light of what is the best return and in the best interest of Kansans.”^[121]
Johnson wrote, “Recent changes in the investment landscape challenge our fiduciary responsibility with how managers are implementing Environmental/Social/Governance (ESG) policies. Further, the changing international landscape, especially with China, demands we consider our exposure and how we take those positions. The treasurer is the elected office that can lead and monitor these decisions to protect Kansas’ best interests.”^[122]

Kentucky

Mike Harmon (Auditor of Public Accounts)

Allison Ball (R) is the Kentucky State Treasurer. She assumed office on January 4, 2016.

Stances on ESG (click to expand)
As auditor Harmon took positions in opposition to environmental, social, and corporate governance (ESG), an approach to investing and corporate decision-making.
State financial officers, including treasurers, auditors, and controllers, are responsible for auditing other government offices, managing payroll, and overseeing pensions. In some states, certain SFOs are also responsible for investing state retirement and trust funds.

Opposition to U.S. Department of Labor ESG rules (December 2021)

In December 2021, Harmon and 35 other state financial officers and attorneys general submitted a public comment to the U.S. Department of Labor (DOL) in opposition to a proposed DOL rule that would encourage financial managers to consider ESG factors when selecting investments for private sector pension plans.^[123]
Titled the “Prudence and Loyalty in Selecting Plan Investments and Exercising Shareholder Rights,” the rule would state that pension plan managers “can make investment decisions that reflect climate change and other environmental, social, or governance (‘ESG’) considerations, including climate-related financial risk, and choose economically targeted investments (‘ETIs’) selected, in part, for benefits apart from the investment return.”^[124]
Harmon and the other officials wrote that the rule “would allow employers and investment managers to invest employee retirement savings in a way that benefits social causes and corporate goals even if it adversely affects the return to the employee” and that it would permit “proxy voting in ways that support ESG investment goals contrary to shareholder interests.”^[125]
The state officials wrote that they were “opposed to investment managers and employers being encouraged or mandated to consider ESG factors and protected from legal action when they do” and that the DOL’s proposed rule “makes what should be a financial decision into a political one.”^[126]

Opposition to Federal Reserve Bank appointee (January 2022)

In January 2022, Harmon was one of 25 members of the State Financial Officers Foundation (SFOF) who co-signed a letter to President Joe Biden, asking him to withdraw the nomination of Sarah Bloom Raskin to the Federal Reserve Bank Board of Governors.^[127]
In a May 2020 New York Times commentary titled “Why Is the Fed Spending So Much Money on a Dying Industry?,” Raskin wrote that Federal Reserve policy decisions should oppose investments in fossil fuels and support investments in the renewable energy sector: “The decisions the Fed makes on our behalf should build toward a stronger economy with more jobs in innovative industries — not prop up and enrich dying ones.”^[128]
Harmon and the signatories on the SFOF letter wrote that they were concerned Raskin “would use the supervisory authority as Vice-Chair for Supervision at the Federal Reserve Bank to disrupt the private banking sector, reliable energy supplies, and the U.S. economy.”^[129]
In March 2022, Raskin withdrew her name from consideration for the Federal Reserve position.^[130]

Letter regarding use of ESG criteria by S&P Global Ratings (June 2022)

In June 2022, Harmon co-signed a letter to the leadership of S&P Global Ratings opposing the firm’s “new plan to include ESG credit indicators in its credit ratings for states and state subdivisions.” The letter was also signed by Kentucky State Treasurer Allison Ball, Kentucky Secretary of State Michael Adams, Kentucky Commissioner of Agriculture Ryan Quarles, and Attorney General of Kentucky Daniel Cameron.^[131]
Harmon and the other signatories wrote that S&P had failed to conduct “cost-benefit-analysis that weighs national security risks and the health of state economies against the need to introduce these ESG factors into its credit ratings.” They also wrote that “subjective, leftist ESG scoring will unquestionably hurt states like Kentucky—where a reduction in coal, oil, and gas production would cause increased unemployment, higher fuel costs, and a decrease in overall tax revenue, thereby negatively impacting Kentucky’s overall creditworthiness and causing undue hardship and suffering for the people of this state.”^[132]

Opposition to Morningstar ratings of Israel investments (August 2022)

In late August 2022, Harmon and 17 other members of the State Financial Officers Foundation (SFOF) co-signed a letter addressed to the Morningstar investment rating service expressing their “serious concern regarding reports that Morningstar, Inc. (Morningstar), through its wholly-owned subsidiary, Sustainalytics, negatively rates firms connected to Israel in apparent alignment with the Boycott, Divestment, Sanctions (BDS) movement.” The letter asserted the BDS movement was “antithetical to the global causes of peace, democracy, and human rights” and asked Morningstar to take corrective action immediately to terminate all research and ratings products that treat Israel-connected companies differently than companies operating in other free democracies.”^[133]

Allison Ball (Treasurer)

As of August 2023, Allison Ball (R) is the Kentucky State Treasurer. She assumed office on January 4, 2016.

Stances on ESG (click to expand)
As treasurer, Ball took positions in opposition to environmental, social, and corporate governance (ESG), an approach to investing and corporate decision-making.
State financial officers, including treasurers, auditors, and controllers, are responsible for auditing other government offices, managing payroll, and overseeing pensions. In some states, certain SFOs are also responsible for investing state retirement and trust funds.

Opposition to Morningstar ratings of Israel investments (August 2022)

In late August 2022, Ball and 17 other members of the State Financial Officers Foundation (SFOF) co-signed a letter addressed to the Morningstar investment rating service expressing their “serious concern regarding reports that Morningstar, Inc. (Morningstar), through its wholly-owned subsidiary, Sustainalytics, negatively rates firms connected to Israel in apparent alignment with the Boycott, Divestment, Sanctions (BDS) movement.” The letter asserted the BDS movement was “antithetical to the global causes of peace, democracy, and human rights” and asked Morningstar to take corrective action immediately to terminate all research and ratings products that treat Israel-connected companies differently than companies operating in other free democracies.”^[134]

Opposition to SEC proposal to mandate ESG reporting (June 2022)

In June 2022, Ball and 22 other state financial officials submitted a comment to the Securities and Exchange Commission (SEC) opposing an SEC rule proposal titled the “Enhancement and Standardization of Climate-Related Disclosures for Investors.” In December 2022, the Pittsburgh Business Times reported that if the SEC rule were finalized it “would become some of the first mandatory environmental, social and governance (ESG) reporting requirements for U.S. companies, requiring the disclosure of climate-related risk information in registration statements and periodic reports.”^[135]^[136]
“We have watched with dismay as the Commission and other federal commissions and boards have proposed rules and policies that promote political causes that will adversely affect public finance and retirement income,” wrote the state financial officers in the letter. “The Proposed Rule is another such rule.”^[137]

Letter regarding use of ESG criteria by S&P Global Ratings (June 2022)

In June 2022, Ball co-signed a letter to the leadership of S&P Global Ratings opposing the firm’s “new plan to include ESG credit indicators in its credit ratings for states and state subdivisions.” The letter was also signed by Kentucky Auditor of Public Accounts Mike Harmon, Kentucky Secretary of State Michael Adams, Kentucky Commissioner of Agriculture Ryan Quarles, and Attorney General of Kentucky Daniel Cameron.^[138]
Ball and the other signatories wrote that S&P had failed to conduct “cost-benefit-analysis that weighs national security risks and the health of state economies against the need to introduce these ESG factors into its credit ratings.” They also wrote that “subjective, leftist ESG scoring will unquestionably hurt states like Kentucky—where a reduction in coal, oil, and gas production would cause increased unemployment, higher fuel costs, and a decrease in overall tax revenue, thereby negatively impacting Kentucky’s overall creditworthiness and causing undue hardship and suffering for the people of this state.”^[139]
“State credit ratings should only be based on finances; they should not be tools to advance political agendas,” said Ball, in a news release regarding the letter. “Injecting political factors of this kind into credit assessments could be particularly detrimental to Kentucky and its signature fossil fuel industries.”^[140]

Letter to Department of Labor regarding use of ESG criteria in ERISA decisions (May 2022)

In May 2022, Ball and 37 state officials from 23 states signed a letter to the U.S. Department of Labor Employment Benefits Security Administration to oppose the implementation of a proposed agency rule. The proposed rule would allow fiduciaries of private pension plans governed by the Employee Retirement Income Security Act (ERISA) to “make investment decisions that reflect climate change and other environmental, social, or governance (“ESG”) considerations, including climate-related financial risk, and choose economically targeted investments (“ETIs”) selected, in part, for benefits apart from the investment return.”^[141]
The signatories objected to the rule, writing that it “would irrationally require fiduciaries to elevate immaterial and speculative risks in employee retirement savings investment decisions” where instead the fiduciaries should be “considering only the material financial or pecuniary factors of each potential investment.”^[142]

Request for AG Opinion regarding ESG criteria (May 2022)

In May 2022, Ball announced that she had requested an official opinion from Attorney General of Kentucky Daniel Cameron "regarding whether 'stakeholder capitalism' and Environmental, Social, and Governance (ESG) investment practices in connection with the investment of public pension funds are consistent with Kentucky law governing fiduciary duties.” The attorney general ruled that the law requires state investment officers to “be single-minded in their motivation and actions and their decisions must be "[s]olely in the interest of the members and beneficiaries [and for] the exclusive purpose of providing benefits[26] to members and beneficiaries,” KRS 61.650(1).”^[143]
“Kentucky should not be the laboratory for stakeholder capitalism and ESG practices. These dangerous policies place political agendas ahead of fiscal priorities and would be at the detriment of pensioners and our Commonwealth,” Ball said, responding to the ruling. “The findings of the Attorney General outline the explicit duty of Kentucky’s pension managers to maximize shareholder value rather than fold to leftist political pressure.”^[144]

Opposition to Federal Reserve Bank appointee (January 2022)

In January 2022, Ball was one of 25 members of the State Financial Officers Foundation (SFOF) who co-signed a letter to President Joe Biden (D), asking him to withdraw the nomination of Sarah Bloom Raskin to the Federal Reserve Bank Board of Governors.^[145]
In a May 2020 New York Times commentary titled, "Why Is the Fed Spending So Much Money on a Dying Industry?," Raskin wrote that Federal Reserve policy decisions should oppose investments in fossil fuels and support investments in the renewable energy sector: "The decisions the Fed makes on our behalf should build toward a stronger economy with more jobs in innovative industries — not prop up and enrich dying ones."^[146]
Ball and the signatories on the SFOF letter wrote that they were concerned Raskin "would use the supervisory authority as Vice-Chair for Supervision at the Federal Reserve Bank to disrupt the private banking sector, reliable energy supplies, and the U.S. economy.”^[147]
In March 2022, Raskin withdrew her name from consideration for the Federal Reserve position.^[148]

Opposition to U.S. Department of Labor ESG rules (December 2021)

In December 2021, Ball and 35 other state financial officers and attorneys general submitted a public comment to the U.S. Department of Labor (DOL) in opposition to a proposed DOL rule that would encourage financial managers to consider ESG factors when selecting investments for private sector pension plans.^[149]
Titled the “Prudence and Loyalty in Selecting Plan Investments and Exercising Shareholder Rights,” the rule would state that pension plan managers "can make investment decisions that reflect climate change and other environmental, social, or governance (‘ESG’) considerations, including climate-related financial risk, and choose economically targeted investments (‘ETIs’) selected, in part, for benefits apart from the investment return.”^[150]
Ball and the other officials wrote that the rule “would allow employers and investment managers to invest employee retirement savings in a way that benefits social causes and corporate goals even if it adversely affects the return to the employee” and that it would permit "proxy voting in ways that support ESG investment goals contrary to shareholder interests.”^[151]
The state officials wrote that they were “opposed to investment managers and employers being encouraged or mandated to consider ESG factors and protected from legal action when they do” and that the DOL’s proposed rule “makes what should be a financial decision into a political one.”^[152]
“I strongly oppose ERISA fiduciaries valuing activism and politics over fiscal responsibility,” said Ball, in a news release regarding the letter. “Permitting subjective environmental, social, and governance considerations to guide investment decisions will be at the detriment of plan beneficiaries. The long-term financial security of retirees should not be sacrificed in favor of irresponsible political action.”^[153]

West Virginia letter supporting financial system access for fuel industry (November 2021)

Ball was also a co-signer on a November 22, 2021, letter sent by West Virginia State Treasurer Riley Moore and addressed: "To Whom It May Concern in the U.S. Banking Industry.” The signatories were the treasurers, auditors and comptrollers from fifteen states. The letter identified them as the "fiduciaries and stewards of more than $600 billion” in combined investment capital.^[154]
The letter began: “We are writing to notify you that we will be taking collective action in response to the ongoing and growing economic boycott of traditional energy production industries by U.S. financial institutions.” The signatories wrote their individual actions would be tailored to fit each state’s unique laws and economic position, but that the coordinated objective would be "to select financial institutions that support a free market and are not engaged in harmful fossil fuel industry boycotts for our states’ financial services contracts.”^[155]

Letter to John Kerry regarding banking access for energy firms (May 2021)

Ball was one of fourteen other state treasurers who co-signed a May 2021 letter sent by West Virginia State Treasurer Riley Moore to Special Presidential Envoy for Climate John Kerry. The treasurers informed Kerry of their concern that he and others in President Joe Biden’s (D) administration were “privately pressuring U.S. banks and financial institutions to refuse to lend to or invest in coal, oil, and natural gas companies, as part of a misguided strategy to eliminate the fossil fuel industry in our country.” The signatories told Kerry that they “strongly oppose the Biden Administration’s efforts to cut off financing for law-abiding industries that are essential to the economy and our citizens’ way of life.”^[156]
According to a March 12, 2021, Politico story referenced in the letter, Kerry was "prodding major U.S. banks privately to announce commitments for climate-friendly finance.” The report also revealed that the Biden administration and several climate policy groups held a March 9, 2022, teleconference to discuss "potential financial sector regulations and executive actions to limit risk from climate change-fueled shocks.” Politico listed representatives from the following groups as participants on the call: the Center for American Progress, Public Citizen, Rainforest Action Network, Sierra Club, and 350.org.^[157]^[158]

Louisiana

John Schroder (Treasurer)

As of August 2023, John Schroder (R) is the Louisiana State Treasurer. He assumed office on December 5, 2017.

Stances on ESG (click to expand)
As treasurer, Schroder took positions in opposition to environmental, social, and corporate governance (ESG), an approach to investing and corporate decision-making.
State financial officers, including treasurers, auditors, and controllers, are responsible for auditing other government offices, managing payroll, and overseeing pensions. In some states, certain SFOs are also responsible for investing state retirement and trust funds.

Exclusion of CitiGroup and Bank of America from Louisiana bond business (August 2018)

In August 2018, Schroder announced that he supported the Louisiana Bond Commission “to prohibit Citigroup and Bank of America from participating in an upcoming bond sale because of their restrictive gun policies.” As state treasurer, Schroder was also the chair of the Bond Commission.^[159]
Both banking firms announced policies that would deny banking services such as loans and credit cards to businesses in the firearms industry.^[160]
“I personally believe the policies of these banks are an infringement on the rights of Louisiana citizens,” said Schorder, in a statement announcing the Bond Commission’s 7-6 vote against the banks. "As a veteran and former member of law enforcement, I take the Second Amendment very seriously.”^[159]

Exclusion of JP Morgan from Louisiana bond business (November 2021)

In November 2021, the Louisiana Bond Commission voted unanimously to refinance $700 million in state borrowing debt through Wells Fargo. Banking firm JP Morgan Chase was initially considered for the deal. Schroder and Louisiana Attorney General Jeff Landry (R), both members of the Bond Commission, opposed giving JP Morgan the contract because the firm’s CEO, Jamie Dimon, had announced that JP Morgan would not do business with manufacturers of popular firearms such as AR-15s. Dimon characterized the rifles as “military-style weapons for civilian use.”^[161]
“I'm not selling our 2nd Amendment rights to corporate America," said Schroder, defending the decision.^[161]

West Virginia letter supporting financial system access for fuel industry (November 2021)

Schroder was a co-signer on a November 22, 2021, letter sent by West Virginia Treasurer Riley Moore (R). The signatories were the treasurers, auditors, and comptrollers from fifteen states. The letter identified them as the “fiduciaries and stewards of more than $600 billion” in combined investment capital.
The letter began: “We are writing to notify you that we will be taking collective action in response to the ongoing and growing economic boycott of traditional energy production industries by U.S. financial institutions.”
The signatories wrote their individual actions would be tailored to fit each state’s unique laws and economic position, but that the coordinated objective would be “to select financial institutions that support a free market and are not engaged in harmful fossil fuel industry boycotts for our states’ financial services contracts.”^[162]

Letter to Unilever CEO regarding Ben & Jerry’s anti-Israel policy (December 2021)

In July 2021, American ice cream maker Ben & Jerry’s announced it would end sales of its products in the “occupied Palestinian territory.” In response, Israeli Prime Minister Naftali Bennett said Ben & Jerry’s had become the “anti-Israel ice cream.”^[163] Ben & Jerry’s is a subsidiary of Unilever, PLC, a publicly traded multinational consumer products conglomerate.
On December 9, 2021, Schroder was one of six other state treasurers co-signing a letter sent by Arizona Treasurer Kimberly Yee (R) to Unilever CEO Alan Jope, accusing him of attempting to “deflect responsibility for Ben & Jerry’s boycott by suggesting that you have no authority over your subsidiary’s decision in this case.” The letter quoted two law professors who had reviewed the Ben & Jerry’s acquisition agreement and found that it required Ben & Jerry’s to “help Unilever sell the premium ice cream in Israel.” The treasurers asked Jope to provide “full clarification and transparency regarding Unilever’s ability to override the discriminatory boycott of Israel initiated by Ben & Jerry’s.”^[164]
In June 2022, Unilever announced it was selling the Israeli rights to the ice cream to American Quality Products (AQP), allowing sales to resume in Israel under the new label. In a Twitter statement, Ben & Jerry’s expressed its disagreement with the policy change, saying, “While our parent company has taken this decision, we do not agree with it. Unilever’s arrangement means Ben & Jerry’s in Israel will be owned and operated by AQP. Our company will no longer profit from Ben & Jerry’s in Israel.”^[165]

Opposition to U.S. Department of Labor ESG rules (December 2021)

In December 2021, Schroder and 35 other state financial officers and attorneys general submitted a public comment to the U.S. Department of Labor (DOL) in opposition to a proposed DOL rule that would encourage financial managers to consider ESG factors when selecting investments for private sector pensionplans.
Titled the “Prudence and Loyalty in Selecting Plan Investments and Exercising Shareholder Rights,” the rule would state that pension plan managers “can make investment decisions that reflect climate change and other environmental, social, or governance (‘ESG’) considerations, including climate-related financial risk, and choose economically targeted investments (‘ETIs’) selected, in part, for benefits apart from the investment return.”
Schroder and the other officials wrote that the rule “would allow employers and investment managers to invest employee retirement savings in a way that benefits social causes and corporate goals even if it adversely affects the return to the employee” and that it would permit “proxy voting in ways that support ESG investment goals contrary to shareholder interests.”
The state officials wrote that they were “opposed to investment managers and employers being encouraged or mandated to consider ESG factors and protected from legal action when they do” and that the DOL’s proposed rule “makes what should be a financial decision into a political one.”^[166]

Opposition to Federal Reserve Bank appointee (January 2022)

In January 2022, Schroder was one of 25 members of the State Financial Officers Foundation (SFOF) who co-signed a letter to President Joe Biden (D), asking him to withdraw the nomination of Sarah Bloom Raskin to the Federal Reserve Bank Board of Governors.^[31]
In a May 2020 New York Times commentary titled “Why Is the Fed Spending So Much Money on a Dying Industry?,” Raskin wrote that Federal Reserve policy decisions should oppose investments in fossil fuels and support investments in the renewable energy sector: “The decisions the Fed makes on our behalf should build toward a stronger economy with more jobs in innovative industries — not prop up and enrich dying ones.”^[167]
Schroder and the signatories on the SFOF letter wrote that they were concerned Raskin “would use the supervisory authority as Vice-Chair for Supervision at the Federal Reserve Bank to disrupt the private banking sector, reliable energy supplies, and the U.S. economy.”^[31]
In March 2022, Raskin withdrew her name from consideration for the Federal Reserve position.^[168]

Letter regarding use of ESG criteria by S&P Global Ratings (May 2022)

In May 2022, Schroder sent a letter to the leadership of S&P Global Ratings, opposing the firm’s policy of publishing “ESG credit indicators as part of its credit ratings for states.”^[169]
“Use of ESG indicators to determine creditworthiness undermines what should be an impartial credit rating system,” said Schroder, according to a press statement regarding the letter. “It changes the trajectory of the rating system from gauging the ability to pay debt to forcing alignment with policy goals.”
The news release headline charged that the “ESG-infused S&P rating process” was “political tyranny.” ^[170]

Opposition to Morningstar ratings of Israel investments (August 2022)

In late August 2022, Schroder and 17 other members of the State Financial Officers Foundation (SFOF) co-signed a letter addressed to the Morningstar investment rating service expressing their “serious concern regarding reports that Morningstar, Inc. (Morningstar), through its wholly-owned subsidiary, Sustainalytics, negatively rates firms connected to Israel in apparent alignment with the Boycott, Divestment, Sanctions (BDS) movement.” The letter said the BDS movement was “antithetical to the global causes of peace, democracy, and human rights” and asked Morningstar to “take corrective action immediately to terminate all research and ratings products that treat Israel-connected companies differently than companies operating in other free democracies.”^[171]

Liquidation of State investments in BlackRock funds (October 2022)

In an October 2022 letter to Larry Fink, CEO of the BlackRock asset management firm, Schroder informed Fink that by the end of the year he would divest all of the $794 million position in BlackRock money market funds, mutual funds and exchange-traded funds held by Louisiana Treasury. Schroder said the investment firm’s “blatantly anti-fossil fuel policies would destroy Louisiana’s economy.”
Schroder also wrote that his legal counsel had informed him that “Environmental, Social and Governance (ESG) investing is contrary to Louisiana law on fiduciary duties, which requires a sole focus on financial returns for the beneficiaries of state funds.”
Fink’s past statements, according to Schorder, demonstrated that BlackRock’s investment policy was in conflict with Louisiana law: “You have admitted that your ESG agenda of forcing behaviors will not increase investor returns. Your 2022 letter to CEOs stated plainly that 'We need to be honest about the fact that green products often come at a higher cost.' High cost/low return environmental policies will reduce a company’s profits...and investors’ returns.”^[172]

Maryland

Brooke Elizabeth Lierman (Comptroller)

As of August 2023, Brooke Elizabeth Lierman (D) is the Maryland Comptroller. She assumed office on January 16, 2023.

Stances on ESG (click to expand)
Lierman took stances in support of environmental, social, and corporate governance (ESG), an approach to investing and corporate decision-making.
State financial officers, including treasurers, auditors, and controllers, are responsible for auditing other government offices, managing payroll, and overseeing pensions. In some states, these financial officers are also responsible for investing state retirement and trust funds.
In her 2022 Candidate Connection survey, Lierman said: “We have a unique opportunity now to reimagine how the Comptroller's office can tackle our state's economic challenges, including the racial wealth divide, public school funding, and climate change, while also building more financially-resilient families and small businesses."^[173]
Lierman said, “Perhaps no threat to our economy and way of life is greater than the threat of climate change. Every elected official in Maryland, including the Comptroller, must be actively engaged in meeting this challenge head on...To prepare for climate change, the State needs a detailed understanding of future impacts, and a long-term strategic plan that outlines the role for all state agencies. Coordination for these actions can begin within the operations of the Office of the Comptroller. Making climate resilience one of the key pillars of the Comptroller’s Office will ensure that all decision-making and functions have a 'climate lens' by which to define future actions.”^[174]
During an October 2022 candidate forum, Lierman said: “The Maryland state retirement and pension system needs to consider the impact of climate change on investment risk and monitor our net zero-line investments in climate solutions to ensure the long-terms sustainability of our investment portfolio."^[175]

Massachusetts

Diana DiZoglio (Auditor)

As of August 2023, Diana DiZoglio (D) is the Massachusetts Auditor of the Commonwealth. She assumed office on January 4, 2023.

Stances on ESG (click to expand)
DiZoglio took positions in support of to environmental, social, and corporate governance (ESG), an approach to investing and corporate decision-making.
State financial officers, including treasurers, auditors, and controllers, are responsible for auditing other government offices, managing payroll, and overseeing pensions. In some states, these financial officers are also responsible for investing state retirement and trust funds.
DiZoglio said: "When it comes to climate change, I am proud of the votes and actions I have taken as a legislator to further our efforts to combat the climate crisis globally while fighting for environmental justice locally. Whether it is my enthusiastic support for both the recently passed Act Driving Climate Policy Forward and last year’s passage of An Act Creating a Next Generation Roadmap for Massachusetts Climate Policy, taking on Columbia Gas after the devastating Merrimack Valley Gas explosion, or fighting against a new natural gas plant in my hometown of Methuen - I have backed up my words with action that has made a difference in residents’ lives. But I know there is so much more our elected leaders can do to set the stage for a true clean energy future. I will be a dedicated partner to all of our environmental champions in this mission.”^[176]

Diversity, Equity, Inclusion (DEI) audits

During her 2022 campaign for state auditor, DiZoglio released a plan for using state audits to advance diversity, equity and inclusion (DEI) policies.^[177]
DiZoglio said: “I will use the Auditor’s office to examine our state contracts and procurement processes to ensure engagement and fair treatment for women-, veteran-, LGBTQ-, and minority-owned businesses."^[177]
She also promised to use DEI-focused audits of state agencies to examine “gender and racial pay disparities within our state government,” racial diversity in retail cannabis licensing, and the implicit bias training provided by law enforcement agencies.^[177]
DiZoglio said: “Too often, big contractors make promises about diversity in their bids but do not follow through. That can be exposed and remedied through effective auditing and reporting.”^[178]

Net-Zero emissions audits

In her 2022 campaign statements, DiZoglio pledged to use audits of state agencies to promote reductions in carbon emissions.^[177]
DiZoglio said: “It is also of the utmost importance that the administration be held accountable on meeting climate goals passed through the ‘Act Creating a Next-Generation Roadmap for Massachusetts Climate Policy. The legislation directed state agencies to set, “interim economy-wide greenhouse gas emissions limits, as well as sector-based emissions sublimits for certain sectors, every five years. It codifies the state’s long-term emissions limit of net-zero emissions by 2050 and directs the adoption of a 2030 emissions limit of ‘at least 50 percent below 1990 levels,’ a 2040 emissions limit of, ‘at least 75 percent below 1990 levels.’ I will audit relevant state agencies to shine a light on where we are, or are not, meeting our commitments.”^[177]

Opposition to use of natural gas

DiZoglio supported a ban on fossil fuel hook-ups in new buildings during her 2022 campaign for auditor. She pledged to prevent the construction of new electrical power plants fueled by natural gas.^[179]
DiZoglio wrote: “In addition, in 2014, LS Power Group planned a new $400 million, 451 MW gas power plant in my hometown of Methuen. As a state representative, I fought against this proposal, and working with concerned citizens and local elected officials the project was stopped and ultimately abandoned. As State Auditor, I will partner with others statewide to fight other, similar proposals in the future. They are contrary to our goals as a Commonwealth and to the needs of our climate and of our world.”^[180]

Deb Goldberg (Treasurer)

As of August 2023, Deb Goldberg (D) is the Massachusetts Treasurer. She assumed office on January 21, 2015.

Stances on ESG (click to expand)
As treasurer, Goldberrg took stances supporting environmental, social, and corporate governance (ESG), an approach to investing and corporate decision-making.
State financial officers, including treasurers, auditors, and controllers, are responsible for auditing other government offices, managing payroll, and overseeing pensions. In some states, these financial officers are also responsible for investing state retirement and trust funds.

Pro-ESG financial officers’ letter opposing anti-ESG state officers (September 2022)

In September 2022, Goldberg and 13 other state and local financial officers signed a letter opposing “legislation aiming to curb consideration of environmental, social and governance (ESG) factors in investing.” The letter said “states in our country have started blacklisting financial firms that don’t agree with their political views,” and cited West Virginia, Idaho, Oklahoma, Texas, and Florida.^[50]
According to a September 2022 report from Financial Technologies Forum, Republican elected officials in 24 states had enacted policies against investing public funds with asset management firms such as BlackRock that had used ESG criteria as a basis for investment decisions.^[181]
Goldberg and the signatories said the following about the anti-ESG legislation: “The blacklisting states apparently believe, despite ample evidence and scientific consensus to the contrary, that poor working conditions, unfair compensation, discrimination and harassment, and even poor governance practices do not represent material threats to the companies in which they invest. They refuse to acknowledge, in the face of sweltering heat, floods, tornadoes, snowstorms and other extreme weather, that climate change is real and is a true business threat to all of us.”^[50]

Proposal to divest pensions from firearms industry (June 2022)

In June 2022, Goldberg asked the Massachusetts General Court to pass a law that would require the Massachusetts Pension Reserves Investment Management (PRIM) Board to divest from firms that produce civilian use firearms and ammunition.^[182]
Goldberg served as the chair of the PRIM board as state treasurer.^[182]
Goldberg said: “It is unacceptable that we as a country continue to live in a seemingly endless cycle of gun violence. Traditional approaches are not working, and we must do what we can to potentially save lives. I implore the Legislature to support the divestment of our public pension funds from gun and ammunition manufacturers and distributors in support of the American people who are victims and survivors of preventable gun violence, just as we did recently by divesting from companies in Russia following their invasion of Ukraine.”^[182]

ESG proxy voting report (June 2022)

In June 2022, Goldberg issued a report on recent ESG-aligned proxy votes taken by the PRIM Board.^[183]
Goldberg said: “One of the strongest tools a pension fund has for engagement is proxy voting. These votes will have a long-term impact on our changing climate while achieving our financial goals.”^[183]
The release included the following examples of PRIM proxy votes:
- Votes in favor of adopting carbon emission reduction targets at Chevron
- Votes against the election of certain board members at The Southern Company
- Votes to “support shareholder resolutions at several financial institutions including, Bank of America, CitiGroup, Goldman Sachs, Morgan Chase, Morgan Stanley, and Wells Fargo to adopt financing policies in line with the International Energy Agency's (IEA) Net Zero by 2050 Scenario.”^[183]
Power to proxy vote against non-ESG corporate directors (February 2022)

In February 2022, the PRIM Board unanimously approved a rule empowering PRIM to cast proxy votes against board members of publicly-traded firms that do not ally with ESG policies. Goldberg, who served as chair, sponsored the resolution.^[184]
A news release from Goldberg’s office said the rule was targeted at “companies that are not aligned with the Paris Climate Agreement and Climate Action 100+” and part of “PRIM’s commitment to build and implement a comprehensive ESG framework with the proxy goals of limiting global warming to 1.5 degrees Celsius and/or establishing a plan to achieve ‘net zero’ emissions by 2050.” Climate Action 100+ is an association of investment firms committed to ESG environmental goals.^[184]^[185]
Goldberg said: “This vote not only benefits our retirees and taxpayers with its positive environmental outcomes, but has significant potential to increase our bottom line. It is a more active approach toward achieving our financial goals while having a productive long-term impact on our changing climate.”^[184]
According to the release, the PRIM board had previously and unanimously adopted Goldberg-sponsored proxy voting rules “focused on renewable energy, human rights standards, executive pay, LGBTQ rights, board diversity and wage equality, and limiting the number of boards a director may sit on.”^[184]

Campaign against JP Morgan Chase board member Lee Raymond (May 2020)

In February 2020, Goldberg and eleven other state treasurers and representatives of state and local public investment funds with investments with JP Morgan Chase opposed the re-election of Lee Raymond to the board of the publicly-traded banking firm. The CEO of Exxon-Mobil until 2005, Raymond had been on the JP Morgan board for 33 years and was an ally of JP Morgan Chase CEO Jamie Dimon. Majority Action, a left-leaning advocacy group, organized the opposition to Raymond's reappointment on the grounds that Raymond denied climate change and had influenced JP Morgan Chase to loan too much money to energy firms that produced carbon emitting fuels. The pressure campaign was organized in advance of the JP Morgan Chase annual shareholder meeting in May 2020.^[186]^[187]
Raymond was reelected to the board for another term that was scheduled to end in May 2021. However, he announced his resignation in December 2020 (effective December 31, 2020). In the regulatory filing announcing the departure, Raymond said it was not as a “result of any disagreement with the company.” Bloomberg News reported that a “spokesman for the bank said Raymond’s retirement has nothing to do with outside pressure.”^[188]^[186]

Minnesota

Julie Blaha (Auditor)

As of August 2023, Julie Blaha (D) is the Minnesota State Auditor. She assumed office on January 1, 2019.

Stances on ESG (click to expand)
Blaha took stances in support of environmental, social, and corporate governance (ESG), an approach to investing and corporate decision-making.
State financial officers, including treasurers, auditors, and controllers, are responsible for auditing other government offices, managing payroll, and overseeing pensions. In some states, these financial officers are also responsible for investing state retirement and trust funds.
As the state auditor, Blaha served as one of four members on the Minnesota State Board of Investment (MSBI). In an August 2022 speech before the board, Blaha said: “Minnesotans know that climate change is real and want to see action. Whether your focus is on protecting the planet or protecting the bottom line, it’s time to increase climate change considerations in Minnesota’s investment strategies.”^[189]

Defending ESG during campaign debate (September 2022)

Blaha and Ryan Wilson, the 2022 Republican nominee for state auditor, argued over ESG policy in a September 2022 election debate.^[190]
Wilson, referencing Blaha’s support for using ESG factors in the MSBI's investment decisions, said, "I will not play politics with our pensions."^[190]
Blaha said: “Even if you don’t care about the environment at all, you need to think about climate change in investments. There are significant risks and there are significant opportunities in how climate is changing and how we’re transitioning energy.”^[190]

Support for SEC proposal to mandate ESG reporting (June 2022)

In June 2022 Blaha and the other three members of the MSBI sent a letter to the Securities and Exchange Commission (SEC) to support an SEC rule proposal titled the “Enhancement and Standardization of Climate-Related Disclosures for Investors.” In December 2022, the Pittsburgh Business Times reported that the SEC rule “would become some of the first mandatory environmental, social and governance (ESG) reporting requirements for U.S. companies, requiring the disclosure of climate-related risk information in registration statements and periodic reports.”^[191]^[192]^[94]
Blaha and the MSBI directors in the letter said: “The MSBI commends the SEC’s attention to and consideration of the challenges that investors face with respect to measuring climate-related risk. We believe uniform disclosure rules provide a consistent framework through which investors may manage risk. To date, all MSBI efforts to measure and engage on climate-related risk have been constrained due to lack of consistent, reliable and comparable information. The MSBI broadly supports the disclosures proposed and believes that fundamentally there is value tied to this information for investors.”^[94]

Support for disinvestment from coal production (May 2020)

Blaha voted for a May 2022 resolution directing the MSBI executive director to remove coal production firms from the MSBI investment portfolio.^[193]
The resolution directed the executive director to remove all “publicly traded companies which derive 25 percent or more of their revenue from the extraction and/or production of thermal coal” from the MSBI’s investment portfolio no later than December 31, 2020.^[194]

Mississippi

David McRae (Treasurer)

As of August 2023, David McRae (R) is the Mississippi Treasurer. He assumed office on January 9, 2020.

Stances on ESG (click to expand)
As treasurer, McRae took positions in opposition to environmental, social, and corporate governance (ESG), an approach to investing and corporate decision-making.
State financial officers, including treasurers, auditors, and controllers, are responsible for auditing other government offices, managing payroll, and overseeing pensions. In some states, certain SFOs are also responsible for investing state retirement and trust funds.
In an October 2022 statement, McRae said, “ESG’s sole promise is to apply ‘Cancel Culture’ to corporate actions,” and that “ESG investors are cherry-picking industry winners and losers, and consumers are paying a hefty price.”
“Regardless of your view on climate change or inclusion or human rights,” he said, “Mississippi’s pension system, taxpayer dollars, and college savings programs are the wrong place to experiment with investment strategies that push balance sheets to the side.”^[195]

Letter to John Kerry regarding banking access for energy firms (May 2021)

McRae was one of fourteen other state treasurers who co-signed a May 2021 letter sent by West Virginia Treasurer Riley Moore (R) to Special Presidential Envoy for Climate John Kerry (D). The treasurers informed Kerry of their concern that he and others in President Joe Biden’s (D) administration were “privately pressuring U.S. banks and financial institutions to refuse to lend to or invest in coal, oil, and natural gas companies, as part of a misguided strategy to eliminate the fossil fuel industry in our country.” The signatories told Kerry that they “strongly oppose the Biden Administration’s efforts to cut off financing for law-abiding industries that are essential to the economy and our citizens’ way of life.”^[159]
According to a March 12, 2021, Politico story referenced in the letter, Kerry was “prodding major U.S. banks privately to announce commitments for climate-friendly finance.” The report also revealed that the Biden administration and several climate policy groups held a March 9, 2022, teleconference to discuss “potential financial sector regulations and executive actions to limit risk from climate change-fueled shocks.” Politico listed representatives from the following groups as participants on the call: the Center for American Progress, Public Citizen, Rainforest Action Network, Sierra Club, and 350.org.^[196]^[159]
“While I will continue to pressure the Biden administration to make decisions that benefit Mississippi workers, I will also closely monitor which financial institutions bow to John Kerry’s demands,” said McRae in a statement from his office. “To put it plainly for those John Kerry has reportedly approached: The people of Mississippi will remember if you work against our families and economy.”^[197]

Letter to Unilever CEO regarding Ben & Jerry’s anti-Israel policy (December 2021)

In July 2021, American ice cream maker Ben & Jerry’s announced it was ending sales of its products in the “occupied Palestinian territory.” In response, Israeli Prime Minister Naftali Bennett said Ben & Jerry’s had become the “anti-Israel ice cream.”^[198]
Ben & Jerry’s is a subsidiary of Unilever, PLC, a publicly traded multinational consumer products conglomerate.
On December 9, 2021, McRae was one of six other state treasurers co-signing a letter sent by Arizona Treasurer Kimberly Yee (R) to Unilever CEO Alan Jope, accusing him of attempting to “deflect responsibility for Ben & Jerry’s boycott by suggesting that you have no authority over your subsidiary’s decision in this case.” The letter cited two law professors who had reviewed the Ben & Jerry’s acquisition agreement and found that it required Ben & Jerry’s to “help Unilever sell the premium ice cream in Israel.” The treasurers asked Jope to provide “full clarification and transparency regarding Unilever’s ability to override the discriminatory boycott of Israel initiated by Ben & Jerry’s.”^[199]
“Ben & Jerry’s decision to boycott Israel was motivated by a misdirected ‘woke’ agenda,” said McRae. “I take the discriminatory economic attack on Israel seriously, as do my colleagues across the country. It’s critical we hold those who can act on this matter accountable.”^[200]
In June 2022, Unilever announced it was selling the Israeli rights to the ice cream to American Quality Products (AQP), allowing sales to resume in Israel under the new label. In a Twitter statement, Ben & Jerry’s expressed its disagreement with the policy change: “While our parent company has taken this decision, we do not agree with it. Unilever’s arrangement means Ben & Jerry’s in Israel will be owned and operated by AQP. Our company will no longer profit from Ben & Jerry’s in Israel.”^[201]
“I took that discriminatory economic attack on Israel seriously and applaud Unilever for having the mettle to reverse its subsidiary’s decision,” said McRae, in a statement following Unilever’s June 2022 decision.^[202]

Opposition to U.S. Department of Labor ESG rules (December 2021)

In December 2021, McRae and 35 other state financial officers and attorneys general submitted a public comment to the U.S. Department of Labor (DOL) in opposition to a proposed DOL rule that would encourage financial managers to consider ESG factors when selecting investments for private sector pension plans.
Titled the “Prudence and Loyalty in Selecting Plan Investments and Exercising Shareholder Rights,” the rule would state that pension plan managers “can make investment decisions that reflect climate change and other environmental, social, or governance (‘ESG’) considerations, including climate-related financial risk, and choose economically targeted investments (‘ETIs’) selected, in part, for benefits apart from the investment return.”
McRae and the other officials wrote that the rule “would allow employers and investment managers to invest employee retirement savings in a way that benefits social causes and corporate goals even if it adversely affects the return to the employee” and that it would permit “proxy voting in ways that support ESG investment goals contrary to shareholder interests.”
The state officials wrote that they were “opposed to investment managers and employers being encouraged or mandated to consider ESG factors and protected from legal action when they do” and that the DOL’s proposed rule “makes what should be a financial decision into a political one.”^[203]

Opposition to Federal Reserve Bank appointee (January 2022)

In January 2022, McRae was one of 25 members of the State Financial Officers Foundation (SFOF) who co-signed a letter to President Joe Biden (D), asking him to withdraw the nomination of Sarah Bloom Raskin to the Federal Reserve Bank Board of Governors.^[79]
In a May 2020 New York Times commentary titled “Why Is the Fed Spending So Much Money on a Dying Industry?,” Raskin wrote that Federal Reserve policy decisions should oppose investments in fossil fuels and support investments in the renewable energy sector: “The decisions the Fed makes on our behalf should build toward a stronger economy with more jobs in innovative industries — not prop up and enrich dying ones.”^[204]
McRae and the signatories on the SFOF letter wrote that they were concerned Raskin “would use the supervisory authority as Vice-Chair for Supervision at the Federal Reserve Bank to disrupt the private banking sector, reliable energy supplies, and the U.S. economy.”^[79]
In a February 2022 statement, McRae said: “If Raskin’s nomination succeeds, this movement will be given one of the most prominent seats at America’s financial table. And if their policies take hold, inflation will worsen. Already high energy costs will skyrocket. And the American people will suffer. Her nomination to the Federal Reserve must be withdrawn.”^[205]
In March 2022, Raskin withdrew her name from consideration for the Federal Reserve position.^[206]

Opposition to Morningstar ratings of Israel investments (August 2022)

In late August 2022, McRae and 17 other members of the State Financial Officers Foundation (SFOF) co-signed a letter addressed to the Morningstar investment rating service expressing their “serious concern regarding reports that Morningstar, Inc. (Morningstar), through its wholly-owned subsidiary, Sustainalytics, negatively rates firms connected to Israel in apparent alignment with the Boycott, Divestment, Sanctions (BDS) movement.” The letter asserted the BDS movement was “antithetical to the global causes of peace, democracy, and human rights” and asked Morningstar to take corrective action immediately to terminate all research and ratings products that treat Israel-connected companies differently than companies operating in other free democracies.”^[207]

Missouri

Scott Fitzpatrick (Auditor)

As of August 2023, Scott Fitzpatrick (R) is the Missouri State Auditor. He assumed office on January 9, 2023.

Stances on ESG (click to expand)
As treasurer, Fitzpatrick took positions in opposition to environmental, social, and corporate governance (ESG), an approach to investing and corporate decision-making.
State financial officers, including treasurers, auditors, and controllers, are responsible for auditing other government offices, managing payroll, and overseeing pensions. In some states, certain SFOs are also responsible for investing state retirement and trust funds.

Opposition to Morningstar ratings of Israel investments (August 2022)

As state treasurer in late August 2022, Fitzpatrick and 17 other members of the State Financial Officers Foundation (SFOF) co-signed a letter addressed to the Morningstar investment rating service expressing their “serious concern regarding reports that Morningstar, Inc. (Morningstar), through its wholly-owned subsidiary, Sustainalytics, negatively rates firms connected to Israel in apparent alignment with the Boycott, Divestment, Sanctions (BDS) movement.” The letter asserted the BDS movement was “antithetical to the global causes of peace, democracy, and human rights” and asked Morningstar to take corrective action immediately to terminate all research and ratings products that treat Israel-connected companies differently than companies operating in other free democracies.”^[208]

Opposition to SEC proposal to mandate ESG reporting (June 2022)

As state treasurer In June 2022, Fitzpatrick and 22 other state financial officials submitted a comment to the Securities and Exchange Commission (SEC) opposing an SEC rule proposal titled the “Enhancement and Standardization of Climate-Related Disclosures for Investors.” In December 2022, the Pittsburgh Business Times reported that if the SEC rule were finalized it “would become some of the first mandatory environmental, social and governance (ESG) reporting requirements for U.S. companies, requiring the disclosure of climate-related risk information in registration statements and periodic reports.”^[209]^[210]
“We have watched with dismay as the Commission and other federal commissions and boards have proposed rules and policies that promote political causes that will adversely affect public finance and retirement income,” wrote the state financial officers in the letter. “The Proposed Rule is another such rule.”^[211]

Letter to Department of Labor regarding use of ESG criteria in ERISA decisions (May 2022)

In May 2022, Fitzpatrick and 37 state officials from 23 states cosigned a letter to the U.S. Department of Labor Employment Benefits Security Administration to oppose the implementation of proposed agency rule. The proposed rule would allow fiduciaries of private pension plans governed by the Employee Retirement Income Security Act (ERISA) to “make investment decisions that reflect climate change and other environmental, social, or governance (“ESG”) considerations, including climate-related financial risk, and choose economically targeted investments (“ETIs”) selected, in part, for benefits apart from the investment return.”^[212]
The cosigners objected to the rule, writing that it “would irrationally require fiduciaries to elevate immaterial and speculative risks in employee retirement savings investment decisions” where instead the fiduciaries should be “considering only the material financial or pecuniary factors of each potential investment.”^[213]

Pro-American Energy Letter to President Biden (April 2022)

In April 2022, Fitzpatrick and 26 other state financial officers cosigned an open letter to President Joe Biden (D) criticizing his administration for promoting an ESG agenda and enacting policies that “thwart the vitality of American energy production.” The letter specifically criticized Biden for canceling the Keystone XL pipeline, disallowing new oil and natural gas leases on federal lands, canceling drilling projects in Alaska and imposing “anti-oil and gas rulemaking from the highest levels of government.”^[214]
“Instead of asking Americans to purchase electric vehicles—which is simply not an option for a great number of American families—government leaders should eliminate barriers to and expand development of these critical resources, bringing down the price of gas at the pump,” wrote the letter signers. “Most Americans cannot afford to purchase an electric vehicle or equip their home with a full set of solar panels, and many in rural America need traditional fuel to run the trucks that service their farms and help feed their communities.”^[215]

Letter to John Kerry regarding banking access for energy firms (May 2021)

Fitzpatrick was one of fourteen state treasurers who co-signed a May 2021 letter sent by West Virginia Treasurer Riley Moore (R) to Special Presidential Envoy for Climate John Kerry. The treasurers informed Kerry of their concern that he and others in Joe Biden’s administration were “privately pressuring U.S. banks and financial institutions to refuse to lend to or invest in coal, oil, and natural gas companies, as part of a misguided strategy to eliminate the fossil fuel industry in our country.” The signatories told Kerry that they “strongly oppose the Biden Administration’s efforts to cut off financing for law-abiding industries that are essential to the economy and our citizens’ way of life.”^[216]
According to a March 12, 2021, Politico story referenced in the letter, Kerry was “prodding major U.S. banks privately to announce commitments for climate-friendly finance.” The report also revealed that the Biden administration and several climate policy groups held a March 9, 2022, teleconference to discuss “potential financial sector regulations and executive actions to limit risk from climate change-fueled shocks.” Politico listed representatives from the following groups as participants on the call: the Center for American Progress, Public Citizen, Rainforest Action Network, Sierra Club, and 350.org.^[217]^[218]
“I can assure you that a financial institution’s decision to choose not to participate as a lender and provider of capital to a certain institution because of political pressure will be a consideration in determining where the state of Missouri puts its money,” Fitzpatrick said.^[219]

Intervention in JPMorgan denial of service to Missouri conservative group (November 2021)

In November 2021, WePay, a payment processing firm owned by JPMorgan Chase, refused to process payments for event tickets being sold by Defense of Liberty, a right-leaning group in Missouri. The event was to feature Donald Trump, Jr. as the speaker. Explaining its refusal to process ticket payments, WePay told Defense of Liberty: “Per our Terms of Service, we are unable to process for hate, violence, racial intolerance, terrorism, the financial exploitation of a crime, or items or activities that encourage, promote, facilitate, or instruct others regarding same.”^[220]
In response, Fitzpatrick sent a letter on November 17, 2022, to JPMorgan Chase CEO Jamie Dimon, urging Dimon to intervene. Fitzpatrick argued that WePay had “failed to provide any additional information or specifics about how the group or this event fall into any of these troubling categories.” Fitzpatrick quoted from WePay’s statement to Defense of Liberty, which said that the “decision is final” and that “information regarding our review process is proprietary so no additional information is available in these instances.”^[220]
“Boycotts, bans and cancellations will not unite us, but listening to those with whom we disagree without preconceived judgements might help,” wrote Fitzpatrick to Dimon. “While as a private business you are free to choose who you want to do business with, it will be the policy of the Missouri State Treasurer’s Office that the state of Missouri will not do business with JP Morgan Chase, or any other financial institution that discriminates against customers based on mainstream political ideology so long as that discrimination continues.”^[220]
In a November 18, 2022, statement JP Morgan Chase announced that the bank “never and would never close an account due to a client’s political affiliation,” and that after “further review, we determined that this organization didn’t violate the terms of service, and we are reaching out to the client to discuss reinstating the account.”^[221]

Opposition to U.S. Department of Labor ESG rules (December 2021)

In December 2021, Fitzpatrick and 35 other state financial officers and attorneys general submitted a public comment to the U.S. Department of Labor (DOL) in opposition to a proposed DOL rule that would encourage financial managers to consider ESG factors when selecting investments for private sector pension plans.^[222]
Titled the “Prudence and Loyalty in Selecting Plan Investments and Exercising Shareholder Rights,” the rule would state that pension plan managers “can make investment decisions that reflect climate change and other environmental, social, or governance (‘ESG’) considerations, including climate-related financial risk, and choose economically targeted investments (‘ETIs’) selected, in part, for benefits apart from the investment return.”^[222]
Fitzpatrick and the other officials wrote that the rule “would allow employers and investment managers to invest employee retirement savings in a way that benefits social causes and corporate goals even if it adversely affects the return to the employee” and that it would permit “proxy voting in ways that support ESG investment goals contrary to shareholder interests.”^[222]
The state officials wrote that they were “opposed to investment managers and employers being encouraged or mandated to consider ESG factors and protected from legal action when they do” and that the DOL’s proposed rule “makes what should be a financial decision into a political one.”^[222]

West Virginia letter supporting financial system access for fuel industry (November 2021)

Fitzpatrick was a co-signer on a November 22, 2021, letter sent by West Virginia Treasurer Riley Moore (R) and addressed: “To Whom It May Concern in the U.S. Banking Industry.” The signatories were the treasurers, auditors and comptrollers from fifteen states. The letter identified them as the “fiduciaries and stewards of more than $600 billion” in combined investment capital.
The letter began: “We are writing to notify you that we will be taking collective action in response to the ongoing and growing economic boycott of traditional energy production industries by U.S. financial institutions.” The signatories wrote their individual actions would be tailored to fit each state’s unique laws and economic position, but that the coordinated objective would be “to select financial institutions that support a free market and are not engaged in harmful fossil fuel industry boycotts for our states’ financial services contracts.”^[223]

Opposition to Federal Reserve Bank appointee (January 2022)

In January 2022, Fitzpatrick was one of 25 members of the State Financial Officers Foundation (SFOF) who co-signed a letter to President Biden, asking him to withdraw the nomination of Sarah Bloom Raskin to the Federal Reserve Bank Board of Governors.^[31]
In a May 2020 New York Times commentary titled “Why Is the Fed Spending So Much Money on a Dying Industry?,” Raskin wrote that Federal Reserve policy decisions should oppose investments in fossil fuels and support investments in the renewable energy sector: “The decisions the Fed makes on our behalf should build toward a stronger economy with more jobs in innovative industries — not prop up and enrich dying ones.”^[224]
Fitzpatrick and the signatories on the SFOF letter wrote that they were concerned Raskin “would use the supervisory authority as Vice-Chair for Supervision at the Federal Reserve Bank to disrupt the private banking sector, reliable energy supplies, and the U.S. economy.”^[31]
In March 2022, Raskin withdrew her name from consideration for the Federal Reserve position.^[225]

Reclaiming state investment fund proxy voting power (June 2022)

In June 2022, the board of the Missouri State Employees' Retirement System (MOSERS) voted to remove proxy voting authority from the investment firms that managed the system’s funds. As treasurer, Fitzpatrick was a member of the board. A news release from the treasurer’s office said that Fitzpatrick had encouraged the board to take back its proxy authority “to protect Missouri State Employee retirement funds from being used by activist investment managers to advance left-wing social and political causes which are harmful to shareholders and violate their fiduciary obligations to Missourians.”^[226]^[227]
In July 2022, Fitzpatrick asked Missouri state lawmakers to “work on legislation to address the impacts of ESG investing and make sure that state pension plans are not allowing their assets to be voted by asset managers that are advancing a woke political agenda.”^[228]

Opposition to Morningstar ratings of Israel investments (August 2022)

In late August 2022, Fitzpatrick and 17 other members of the State Financial Officers Foundation (SFOF) co-signed a letter addressed to the Morningstar investment rating service expressing their “serious concern regarding reports that Morningstar, Inc. (Morningstar), through its wholly-owned subsidiary, Sustainalytics, negatively rates firms connected to Israel in apparent alignment with the Boycott, Divestment, Sanctions (BDS) movement.” The letter asserted the BDS movement was “antithetical to the global causes of peace, democracy, and human rights” and asked Morningstar to take corrective action immediately to terminate all research and ratings products that treat Israel-connected companies differently than companies operating in other free democracies.”^[229]
“Missouri has clear anti-BDS laws and these allegations are troubling,” Fitzpatrick said. “Not only is Israel an important democratic ally, but once again, we are faced with a company entrusted to provide non-partisan research and ratings betraying that trust to further a political agenda.”^[230]

Montana

Troy Downing (Commissioner of Securities and Insurance, State Auditor)

As of August 2023, Troy Downing (R) is the Montana Commissioner of Securities and Insurance, State Auditor. He assumed office on January 4, 2021.

Stances on ESG (click to expand)
As state auditor, Downing took positions in opposition to environmental, social, and corporate governance (ESG), an approach to investing and corporate decision-making.
State financial officers, including treasurers, auditors, and controllers, are responsible for auditing other government offices, managing payroll, and overseeing pensions. In some states, certain SFOs are also responsible for investing state retirement and trust funds.
In June 2022, Downing sent a comment letter to Gary Gensler, chair of the Securities and Exchange Commission (SEC), opposing recently proposed SEC rules that would require publicly traded companies to monitor and report their greenhouse gas emissions. Downing wrote that the “proposed rules have potentially devastating impacts on natural resource development, energy production, agriculture, and the jobs of thousands of Montana workers who depend on these industries.” Downing also asked “whether the SEC, in its role as securities regulator, has the jurisdiction or authority to mandate climate disclosures or whether the cost-benefit analyses in the proposed rules meet the requirements of the Administrative Procedure Act.”^[231]

Nebraska

John Murante (Treasurer)

As of August 2023, John Murante (R) is the Nebraska Treasurer. He assumed office on January 9, 2019.

Stances on ESG (click to expand)
Murante has taken positions in opposition to Environmental, social, and corporate governance (ESG), an approach to investing and corporate decision-making.
State financial officers, including treasurers, auditors, and controllers, are responsible for auditing other government offices, managing payroll, and overseeing pensions. In some states, certain SFOs are also responsible for investing state retirement and trust funds.

Opposition to Morningstar ratings of Israel investments (August 2022)

In August 2022, Senator John Murante and 17 members of the State Financial Officers Foundation (SFOF) co-signed a letter to Morningstar, expressing concerns about Morningstar's subsidiary, Sustainalytics, negatively rating companies connected to Israel. They believed this aligned with the BDS movement, which they considered contrary to global peace, democracy, and human rights. The letter urged Morningstar to cease differential treatment of Israel-connected companies in its research and ratings.”^[232]

Opposition to SEC proposal to mandate ESG reporting (June 2022)

In June 2022, Murante and 22 other state financial officials submitted a comment to the Securities and Exchange Commission (SEC) opposing an SEC rule proposal titled the “Enhancement and Standardization of Climate-Related Disclosures for Investors.” In December 2022, the Pittsburgh Business Times reported that if the SEC rule were finalized it “would become some of the first mandatory environmental, social and governance (ESG) reporting requirements for U.S. companies, requiring the disclosure of climate-related risk information in registration statements and periodic reports.”^[233]^[234]
“We have watched with dismay as the Commission and other federal commissions and boards have proposed rules and policies that promote political causes that will adversely affect public finance and retirement income,” wrote the state financial officers in the letter. “The Proposed Rule is another such rule.”^[235]

Letter to Department of Labor regarding use of ESG criteria in ERISA decisions (May 2022)

In May 2022, Murante and 37 state officials from 23 states cosigned a letter to the U.S. Department of Labor Employment Benefits Security Administration to oppose the implementation of proposed agency rule. The proposed rule would allow fiduciaries of private pension plans governed by the Employee Retirement Income Security Act (ERISA) to “make investment decisions that reflect climate change and other environmental, social, or governance (“ESG”) considerations, including climate-related financial risk, and choose economically targeted investments (“ETIs”) selected, in part, for benefits apart from the investment return.”^[236]
The cosigners objected to the rule, writing that it “would irrationally require fiduciaries to elevate immaterial and speculative risks in employee retirement savings investment decisions” where instead the fiduciaries should be “considering only the material financial or pecuniary factors of each potential investment.”^[237]

Pro-American Energy Letter to President Biden (April 2022)

In April 2022, Murante and 26 other state financial officers cosigned an open letter to President Joe Biden (D) criticizing his administration for promoting an ESG agenda and enacting policies that “thwart the vitality of American energy production.” The letter specifically criticized Biden for canceling the Keystone XL pipeline, disallowing new oil and natural gas leases on federal lands, canceling drilling projects in Alaska and imposing “anti-oil and gas rulemaking from the highest levels of government.”^[238]
“Instead of asking Americans to purchase electric vehicles—which is simply not an option for a great number of American families—government leaders should eliminate barriers to and expand development of these critical resources, bringing down the price of gas at the pump,” wrote the letter signers. “Most Americans cannot afford to purchase an electric vehicle or equip their home with a full set of solar panels, and many in rural America need traditional fuel to run the trucks that service their farms and help feed their communities.”^[239]

Opposition to Federal Reserve Bank appointee (January 2022)

In January 2022, Murante was one of 25 members of the State Financial Officers Foundation (SFOF) who co-signed a letter to President Biden (D), asking him to withdraw the nomination of Sarah Bloom Raskin to the Federal Reserve Bank Board of Governors.^[31]
In a May 2020 New York Times commentary titled “Why Is the Fed Spending So Much Money on a Dying Industry?,” Raskin wrote that Federal Reserve policy decisions should be biased against the fossil fuel industry: “The decisions the Fed makes on our behalf should build toward a stronger economy with more jobs in innovative industries — not prop up and enrich dying ones.”^[240]
Murante and the signatories on the SFOF letter wrote that they were concerned Raskin “would use the supervisory authority as Vice-Chair for Supervision at the Federal Reserve Bank to disrupt the private banking sector, reliable energy supplies, and the U.S. economy.”^[31]
In March 2022, Raskin withdrew her name from consideration for the Federal Reserve position.^[241]

Letter to Unilever CEO regarding Ben & Jerry’s anti-Israel policy (December 2021)

In July 2021, American ice cream maker Ben & Jerry’s announced it was ending sales of its products in the “occupied Palestinian territory.” In response, Israeli Prime Minister Naftali Bennett said Ben & Jerry’s had become the “anti-Israel ice cream.”^[242]
Ben & Jerry’s is a subsidiary of Unilever, PLC, a publicly traded multinational consumer products conglomerate.
On December 9, 2021, Murante was one of six other state treasurers co-signing a letter sent by Arizona State Treasurer Kimberly Yee (R) to Unilever CEO Alan Jope, accusing him of attempting to “deflect responsibility for Ben & Jerry’s boycott by suggesting that you have no authority over your subsidiary’s decision in this case.” The letter cited two law professors who had reviewed the Ben & Jerry’s acquisition agreement and found that it required Ben & Jerry’s to “help Unilever sell the premium ice cream in Israel.” The treasurers asked Jope to provide “full clarification and transparency regarding Unilever’s ability to override the discriminatory boycott of Israel initiated by Ben & Jerry’s.”^[243]
In June 2022, Unilever announced it was selling the Israeli rights to the ice cream to American Quality Products (AQP), allowing sales to resume in Israel under the new label. In a Twitter statement, Ben & Jerry’s expressed its disagreement with the policy change: “While our parent company has taken this decision, we do not agree with it. Unilever’s arrangement means Ben & Jerry’s in Israel will be owned and operated by AQP. Our company will no longer profit from Ben & Jerry’s in Israel.”^[244]

Opposition to U.S. Department of Labor ESG rules (December 2021)

In December 2021, Murante and 35 other state financial officers and attorneys general submitted a public comment to the U.S. Department of Labor (DOL) in opposition to a proposed DOL rule that would encourage financial managers to consider ESG factors when selecting investments for private sector pension plans.
Titled the “Prudence and Loyalty in Selecting Plan Investments and Exercising Shareholder Rights,” the rule would state that pension plan managers “can make investment decisions that reflect climate change and other environmental, social, or governance (‘ESG’) considerations, including climate-related financial risk, and choose economically targeted investments (‘ETIs’) selected, in part, for benefits apart from the investment return.”
Murante and the other officials wrote that the rule “would allow employers and investment managers to invest employee retirement savings in a way that benefits social causes and corporate goals even if it adversely affects the return to the employee” and that it would permit “proxy voting in ways that support ESG investment goals contrary to shareholder interests.”
The state officials wrote that they were “opposed to investment managers and employers being encouraged or mandated to consider ESG factors and protected from legal action when they do” and that the DOL’s proposed rule “makes what should be a financial decision into a political one.”^[245]

West Virginia letter supporting financial system access for fuel industry (November 2021)

Murante was a co-signer on a November 22, 2021, letter sent by West Virginia State Treasurer Riley Moore (R) and addressed: “To Whom It May Concern in the U.S. Banking Industry.” The signatories were the treasurers, auditors and comptrollers from fifteen states. The letter identified them as the “fiduciaries and stewards of more than $600 billion” in combined investment capital.
The letter began: “We are writing to notify you that we will be taking collective action in response to the ongoing and growing economic boycott of traditional energy production industries by U.S. financial institutions.” The signatories wrote their individual actions would be tailored to fit each state’s unique laws and economic position, but that the coordinated objective would be “to select financial institutions that support a free market and are not engaged in harmful fossil fuel industry boycotts for our states’ financial services contracts.”^[246]

Letter to John Kerry regarding banking access for energy firms (May 2021)

Murante was one of fourteen other state treasurers who co-signed a May 2021 letter sent by West Virginia State Treasurer Riley Moore (R) to Special Presidential Envoy for Climate John Kerry (D). The treasurers informed Kerry of their concern that he and others in President Joe Biden’s (D) administration were “privately pressuring U.S. banks and financial institutions to refuse to lend to or invest in coal, oil, and natural gas companies, as part of a misguided strategy to eliminate the fossil fuel industry in our country.” The signatories told Kerry that they “strongly oppose the Biden Administration’s efforts to cut off financing for law-abiding industries that are essential to the economy and our citizens’ way of life.”^[94]
According to a March 12, 2021, Politico story referenced in the letter, Kerry was “prodding major U.S. banks privately to announce commitments for climate-friendly finance.” The report also revealed that the Biden administration and several climate policy groups held a March 9, 2022, teleconference to discuss “potential financial sector regulations and executive actions to limit risk from climate change-fueled shocks.” Politico listed representatives from the following groups as participants on the call: the Center for American Progress, Public Citizen, Rainforest Action Network, Sierra Club and 350.org.^[247]^[94]

Nevada

Zach Conine (Treasurer)

As of August 2023, Zach Conine (D) is the Nevada State Treasurer. He assumed office on January 7, 2019.

Stances on ESG (click to expand)
As treasurer, Conine took stances supporting Environmental, social, and corporate governance (ESG), an approach to investing and corporate decision-making.
State financial officers, including treasurers, auditors, and controllers, are responsible for auditing other government offices, managing payroll, and overseeing pensions. In some states, certain SFOs are also responsible for investing state retirement and trust funds.

Criticism of Texas anti-ESG policy (December 2022)

In a December 2022 interview published in The Bond Buyer, Conine criticized the state of Texas for divesting from banks and financial firms with ESG policies, but supported the state’s right to make such decisions.
“Look at Texas, and the studies that have been done on the additional cost of issuance, because they banned underwriters based on their positions on ESG,” said Conine in the interview. “That is costing Texas billions of dollars on spreads on issuance. It was a bad fiduciary decision, but it is in the universe of decisions a treasurer can make.”^[248]
According to Bloomberg, a 2021 Texas state law “requires public pensions to divest from financial companies that have been labeled as 'boycotting' fossil fuels.”^[249]
An analysis prepared by the Texas Senate Research Center says the law “prohibits Texas state agencies that invest funds from investing in financial companies that boycott energy companies” and “requires the Comptroller of Public Accounts of the State of Texas (comptroller) to prepare and maintain a list of all financial companies that refuse to deal with, terminate business activities with, or otherwise take any action that is, solely or primarily, intended to penalize, inflict economic harm on, or limit commercial relations with a financial company because the company engages in the exploration, production, utilization, transportation, sale, or manufacturing of fossil fuel-based energy and does not commit or pledge to meet environmental standards beyond applicable federal and state law.”^[250]
“If it is a value within the state, then they should represent it, but from a fiduciary perspective, and how much it is costing the state, I don’t think it’s a good position to take,” said Conine, of the Texas law. “We divested from firearms because we thought it was a risky investment, but I also want to live in a state with less gun violence, and one way to do that is to not invest in gun manufacturing. Divesting from a liability is recognizing a market force. Banning companies from working in your state is a political choice, not a market decision. It was their choice. I just wouldn’t have done the same.”^[251]

Pro-ESG financial officers’ letter opposing anti-ESG state officers (September 2022)

In September 2022, Conine and 13 other state and local financial officers co-signed a letter opposing the actions of states that had passed “legislation aiming to curb consideration of environmental, social and governance (ESG) factors in investing.” The letter asserted that “states in our country have started blacklisting financial firms that don’t agree with their political views,” and cited in particular “West Virginia, Idaho, Oklahoma, Texas, and Florida” for “using blacklists to obstruct the free market.”^[50]
According to a September 2022 report from Financial Technologies Forum, Republican elected officials in 24 states had enacted policies against investing public funds with asset management firms such as BlackRock that had used ESG criteria as a basis for investment decisions.^[252]
Conine and the signatories alleged the following about the anti-ESG legislation: “The blacklisting states apparently believe, despite ample evidence and scientific consensus to the contrary, that poor working conditions, unfair compensation, discrimination and harassment, and even poor governance practices do not represent material threats to the companies in which they invest. They refuse to acknowledge, in the face of sweltering heat, floods, tornadoes, snowstorms and other extreme weather, that climate change is real and is a true business threat to all of us.”^[50]

Nevada divestment from firearms investments (June 2022)

In June 2022, Conine issued a news release announcing he would divest the state “investment portfolio from companies that manufacture or sell assault-style weapons.”^[253]
“As Nevada’s chief investment officer, I have a responsibility to ensure Nevada’s tax dollars are invested with minimal exposure to risk,” said Conine, according to the news release. “Companies that profit on the manufacture and sale of assault-style weapons present a market risk I’m not willing to take. Investments are fundamentally a plan for the future, and it's time Nevada started investing in a better future where our children aren't slaughtered in classrooms.”^[254]
An initial review by the Nevada Treasurer’s Office identified $89 million in investments in firms the staff believed would be subject to the divestment policy. ^[255]
The news release and media reports did not stipulate how Conine’s policy had differentiated “assault weapons” and “assault-style weapons” from other firearms commonly and legally owned by American citizens. In one example, a December 2022 report in The Bond Buyer claimed Conine had divested the state “from automatic weapons and gun manufacturers.” Automatic weapons have been tightly regulated, heavily taxed, and as a general rule not legally possessed by most law-abiding Americans since passage of the National Firearms Act of 1934.^[256]^[257]^[258]^[259]^[260]
“Today, I directed our team to divest the State of Nevada from any investment in a business that profits from the sale or manufacture of assault-style weapons,” said Conine in a social media post announcing his divestment policy. “No one policy or law will fix this crisis, but we all must do something.”^[261]

New York

Thomas DiNapoli (Comptroller)

Also of August 2023, Thomas P. DiNapoli (D) is the New York Comptroller. He assumed office on February 7, 2007.

Stances on ESG (click to expand)
DiNapoli took stances in support of Environmental, social, and corporate governance (ESG), an approach to investing and corporate decision-making.
State financial officers, including treasurers, auditors, and controllers, are responsible for auditing other government offices, managing payroll, and overseeing pensions. In some states, certain SFOs are also responsible for investing state retirement and trust funds.

Approval of stronger proxy vote policy regarding corporate boards (April 2022)

An April 2022 news release from the state comptroller’s office announced that DiNapoli had approved new proxy voting guidelines for the New York State Common Retirement Fund that would expand “scrutiny of board directors at companies that fail to address climate risks” and incorporate “expectations related to alignment with net zero and the Paris Agreement goals.”^[262]
Assessing New York State Common Retirement Fund climate policy proxy votes for 2021, the news release reported that the fund, under DiNapoli’s direction as trustee, had “voted against 404 individual directors at 88 companies, including Berkshire Hathaway, Chevron Corporation, Phillips 66, Reliance Steel and Caterpillar Inc.”^[263]

Support for SEC proposal to mandate ESG reporting (March 2022)

In June 2022, DiNapoli announced he would support a Securities and Exchange Commission (SEC) rule proposal titled the “Enhancement and Standardization of Climate-Related Disclosures for Investors.” In December 2022, the Pittsburgh Business Times reported that if the SEC rule were finalized it “would become some of the first mandatory environmental, social and governance (ESG) reporting requirements for U.S. companies, requiring the disclosure of climate-related risk information in registration statements and periodic reports.”^[264]^[265]
“We are all experiencing catastrophic and deadly weather events, droughts, rising sea levels, and economic disruption due to climate change,” said DiNapoli, in a news release. “It is time for US companies to step up to the plate and develop, disclose and implement low carbon transition plans. It is our responsibility as investors to make sure the companies we invest in are prepared for the future, so they can be profitable and successful in the global marketplace. To do so requires us to have the information necessary to make informed investment decisions. Today's SEC rule does just that.”^[266]
DiNapoli and former California Controller Betty Yee (Democratic Party) jointly authored a June 2021 opinion piece in Politico calling for the SEC to impose climate disclosure rules on public firms.^[267]

Divestment from energy-producing companies (February 2022)

In February 2022, DiNapoli announced the state would divest from $238 million in investments in 21 publicly-traded oil and gas producers. A news release charged the 21 firms with failure “to demonstrate they are prepared for the transition to a low-carbon economy.” The release also reported the decision to divest was “part of DiNapoli’s comprehensive Climate Action Plan to address investment risks from climate change and his commitment to transition the Fund’s investment portfolio to net zero greenhouse gas emissions by 2040.” The Office of the New York Comptroller evaluated 42 energy companies and found 21 it believed had “failed to show viable transition strategies.”^[268]
This followed a similar decision by DiNapoli in April 2021 to divest the state from positions in five oil companies; and a 2020 decision to divest from 22 publicly-traded corporations involved in producing energy from coal. In August 2021, DiNapoli announced the addition of five additional coal producers to the state’s divestment list.^[269]^[270]
“As nations around the world become increasingly serious about addressing the threat of climate change and as market forces drive a low-carbon economic transition, we need to make sure our investments line up with this reality,” said DiNapoli, in April 2021.^[271]

Support for ESG board seats at Exxon-Mobil (May 2021)

The New York State Comptroller is the trustee of the New York State Common Retirement Fund. In May 2021, as retirement fund trustee, DiNapoli sided with a group of activist shareholders who successfully replaced three members of the board of the energy firm ExxonMobil. The election campaign for the new board members was launched by the hedge-fund Engine No. 1, and was based in part on Engine No. 1’s belief that ExxonMobil was not sufficiently adjusting for climate change and what Engine No. 1 asserted would be a declining demand for fossil fuel. Engine No. 1 won support for its position from large money management firms BlackRock, Vanguard and State Street Global Advisors.^[272]^[273]
“The fact that Exxon hasn’t been responsive up until now, in a way they set the stage for their own defeat,” said DiNapoli.^[274]
In December 2018, as trustee of the retirement fund, DiNapoli supported an ExxonMobil shareholder resolution calling on the energy firm to set and disclose greenhouse gas emissions reduction targets in compliance with the Paris Climate Agreement.^[275]
In May 2019, DiNapoli supported an ExxonMobil shareholder resolution calling for the firm to separate the CEO and board chair positions. In a news release announcing support for the vote, he said ExxonMobil’s leadership had created a “governance crisis” because they had failed “to adequately address significant shareholder concerns and properly account for climate risk.”^[276]

$400 million investment in solar and wind energy funds (April 2021)

In April 2021, DiNapoli announced New York State Common Retirement Fund would invest $400 million in two investment funds that invest in the production of solar and wind energy. In a news release, DiNapoli’s office reported the investment was “tied to DiNapoli’s comprehensive Climate Action Plan to lower investment risks from climate change and transition the portfolio to net zero greenhouse gas emissions.”^[277]
The state retirement fund purchased a $300 million position in Copenhagen Infrastructure Partners IV, and $100 million in Excelsior Renewable Energy Investment Fund I.^[278]
“While climate change poses investment risks, it also creates opportunities for the state pension fund to invest in the companies and funds that are best positioned for the low-carbon future,” said DiNapoli, according to the release. “The commitments we announced today aim to take advantage of the growth in climate investing and to strengthen our portfolio for the long-term.”^[279]

Adoption of 2040 net-zero goal for state retirement fund (December 2020)

A December 2020 news release from the state comptroller’s office announced that the New York State Common Retirement Fund had “adopted a goal to transition its portfolio to net zero greenhouse gas emissions by 2040.”^[280]
DiNapoli, the trustee of the state retirement fund, said achieving the goal could include divestment from energy firms.
“New York State’s pension fund is at the leading edge of investors addressing climate risk, because investing for the low-carbon future is essential to protect the fund’s long-term value,” DiNapoli said in the news release. “Achieving net-zero carbon emissions by 2040 will put the Fund in a strong position for the future mapped out in the Paris Agreement. We continue to assess energy sector companies in our portfolio for their future ability to provide investment returns in light of the global consensus on climate change. Those that fail to meet our minimum standards may be removed from our portfolio. Divestment is a last resort, but it is an investment tool we can apply to companies that consistently put our investment’s long-term value at risk.^[281]

Hiring of director of sustainable investments and climate solutions (January 2020)

In January 2020, DiNapoli announced the New York State Common Retirement Fund had hired Andrew Siwo as its first-ever director of sustainable investments and climate solutions. A news release reported Siwo’s mission would be to “support the implementation of the Fund’s Climate Action Plan.”^[282]
“We are fortunate to have Andrew Siwo’s experience and expertise to help advance the Fund’s ongoing pursuit of smart climate-related investments,” DiNapoli said, according to the news release. “Climate change is an increasingly urgent risk facing all investors, and I am determined to protect New York State’s pension fund by keeping it at the forefront of those addressing it. Andrew will be a great asset in sourcing investment opportunities in the growing lower carbon global economy.”^[283]
Siwo, according to the news release, had previously been the “investment director and head of Mission-Related Investing at Colonial Consulting, focusing on SRI, ESG and impact investments.”^[284]

Adoption of Climate Action Plan for state retirement fund (June 2019)

In June 2019, DiNapoli released a “Climate Action Plan” to guide investment decisions for the New York State Common Retirement Fund which, at the time, had $210 billion in assets. The plan committed the state retirement fund to invest $20 billion over ten years in “sustainable investments.”^[285]
“Climate change is one of the most significant risks facing investors and the warnings are growing increasingly dire,” DiNapoli said. “The Fund has taken many steps to assess and address climate risk already, but clearly more must be done and done quickly. This is a proactive plan to mitigate climate risk, capitalize on opportunities in the growing low carbon economy and protect the fund’s long term value.”^[286]

SEC petition seeking mandatory ESG reporting from public firms (October 2018)

In October 2018, DiNapoli was a co-signatory on a petition to the Securities and Exchange Commission (SEC) requesting that the federal regulatory agency impose “rulemaking to develop mandatory rules for public companies to disclose high-quality, comparable, decision-useful environmental, social, and governance information.”^[287]
The letter acknowledged that “most of America’s largest public companies” were already “attempting to provide additional information” on ESG issues. But the signatories also alleged there were “substantial problems with the nature, timing, and extent of these voluntary disclosures,” and “problems with the quality of voluntary ESG disclosure.”^[288]
The petition was written by Prof. Cynthia A Williams of the Osgoode Hall Law School, and Prof. Jill E Fisch of the University of Pennsylvania Law School. Co-signers included public and private investment officials claiming to represent $5 trillion in assets under management.^[289]

Brad Lander (NYC Comptroller)

As of August 2023, Brad Lander (D) is the New York City Comptroller. He assumed office on January 1, 2022.

Stances on ESG (click to expand)
Lander took positions in support of the Environmental, social, and corporate governance (ESG) movement.

Proxy votes against energy production financing (January 2023)

In January 2023, Lander and the leadership of New York City’s three municipal pension funds announced they would vote in favor of shareholder resolutions proposing reductions in fossil fuel financing by large banking firms.^[290]
According to a news release from Lander’s office, the proxy proposals called for the banks to create and disclose their plans to reduce their greenhouse gas emissions to meet specific targets in 2030.
The release said, “the proposals filed at Goldman Sachs, JPMorgan Chase and Royal Bank of Canada specifically request that the absolute GHG emissions targets cover lending and underwriting for oil and gas and power generation sectors. The proposal at Bank of America, co-filed with the New York State Common Retirement Fund, requests that the GHG emissions reduction targets cover lending and underwriting in the Company’s energy sector.”^[290]
Landers was quoted in the release, saying: “Shareholders applauded these banks when they set net zero goals – but it can’t be all talk. We expect them to take the steps needed now to reduce emissions on the timeline to which they have committed. We are asking Bank of America, JPMorgan Chase, Goldman Sachs, and Royal Bank of Canada to follow the lead of their peers by setting and disclosing absolute, science-based targets for 2030, to show investors they are serious about reaching those goals. Absent a concrete plan to reduce absolute emissions in the real world in the near term, any net zero plan rings hollow.”^[290]
Similarly, in April 2022, Lander announced on behalf of the city retirement systems that they would support “shareholder proposals that urge financial institutions to adopt policies that eliminate financing of new fossil fuel exploration and development.” The resolutions targeted Bank of America, Goldman Sachs, Citi Group, and Wells Fargo.^[291]

Pro-ESG financial officers’ letter opposing anti-ESG state officers (September 2022)

In September 2022, Lander and 13 other state and local financial officers signed a letter opposing “legislation aiming to curb consideration of environmental, social and governance (ESG) factors in investing.” The letter said “states in our country have started blacklisting financial firms that don’t agree with their political views,” and cited West Virginia, Idaho, Oklahoma, Texas, and Florida.”^[50]
According to a September 2022 report from Financial Technologies Forum, Republican elected officials in 24 states had enacted policies against investing public funds with asset management firms, such as BlackRock, that had used ESG criteria as a basis for investment decisions.^[292]
Lander and the signatories alleged the following about the anti-ESG legislation: “The blacklisting states apparently believe, despite ample evidence and scientific consensus to the contrary, that poor working conditions, unfair compensation, discrimination and harassment, and even poor governance practices do not represent material threats to the companies in which they invest. They refuse to acknowledge, in the face of sweltering heat, floods, tornadoes, snowstorms and other extreme weather, that climate change is real and is a true business threat to all of us.”^[50]

Support for stronger ESG commitment from BlackRock (September 2022)

In a September 2022 letter to BlackRock CEO Larry Fink, Lander said he was concerned “BlackRock is backtracking on its climate commitments, to the detriment of its portfolio, New York City’s pension funds, and our planet.”^[293]
BlackRock, a global investment manager and fiduciary, supported ESG investing. In a 2020 report to investors the firm announced that it had “delivered on its goal of having 100% of our approximately 5,600 active and advisory BlackRock strategies ESG integrated—covering U.S. $2.7 trillion in assets.”^[294]
Lander said: “BlackRock now abdicates responsibility for driving net zero alignment in its own portfolio by saying that it does not ask companies to set specific emissions targets, and that its participation in NZAMI does not mean BlackRock is setting or meeting any net zero targets. BlackRock even goes so far as to tout its continued investment in fossil fuels—without specific net zero targets or commitments or any plan for a phased transition away from the very investments that increase carbon emissions—as somehow a necessary part of a transition to a green economy.”^[295]

Support for SEC proposal to mandate ESG reporting (March 2022)

In March 2022 Lander announced his support for a Securities and Exchange Commission (SEC) rule proposal titled the “Enhancement and Standardization of Climate-Related Disclosures for Investors.” In December 2022, the Pittsburgh Business Times reported that if the SEC rule were finalized it “would become some of the first mandatory environmental, social and governance (ESG) reporting requirements for U.S. companies, requiring the disclosure of climate-related risk information in registration statements and periodic reports.”^[296]^[297]^[298]
Landers said: "For too long, disclosure of climate risk information by publicly traded companies has been voluntary and without uniform standards. As a result, investors lack the information needed to evaluate the financial risks to their portfolios or potential investments posed by physical climate impacts like rising seas, floods, and wildfires, as well as policy impacts from companies and governments alike enacted to reduce emissions and exposure to climate threats.”^[299]
In June 2022, 23 Republican state financial officials submitted a comment to the SEC opposing the rule.^[300] The comment said: “We have watched with dismay as the Commission and other federal commissions and boards have proposed rules and policies that promote political causes that will adversely affect public finance and retirement income,” wrote the state financial officers in the letter. “The Proposed Rule is another such rule.”^[301]

North Carolina

Dale Folwell (Treasurer)

As of August 2023, Dale Folwell (R) is the North Carolina Treasurer. He assumed office on January 1, 2017.

Stances on ESG (click to expand)
As auditor, Folwell took positions in opposition to environmental, social, and corporate governance (ESG), an approach to investing and corporate decision-making.
State financial officers, including treasurers, auditors, and controllers, are responsible for auditing other government offices, managing payroll, and overseeing pensions. In some states, certain SFOs are also responsible for investing state retirement and trust funds.

Opposition to Federal Reserve Bank appointee (January 2022)

In January 2022, Folwell was one of 25 members of the State Financial Officers Foundation (SFOF) who co-signed a letter to President Joe Biden (D), asking him to withdraw the nomination of Sarah Bloom Raskin to the Federal Reserve Bank Board of Governors.^[31]
In a May 2020 New York Times commentary titled “Why Is the Fed Spending So Much Money on a Dying Industry?,” Raskin wrote that Federal Reserve policy decisions should oppose investments in fossil fuels and support investments in the renewable energy sector: “The decisions the Fed makes on our behalf should build toward a stronger economy with more jobs in innovative industries — not prop up and enrich dying ones.”^[302]
Folwell and the signatories on the SFOF letter wrote that they were concerned Raskin “would use the supervisory authority as Vice-Chair for Supervision at the Federal Reserve Bank to disrupt the private banking sector, reliable energy supplies, and the U.S. economy.”^[31]
In March 2022, Raskin withdrew her name from consideration for the Federal Reserve position.^[303]

Reclaiming Voting Proxy for State Pension Funds (July 2022)

A July 2022 profile in the investment website Top 1000 Funds reported Folwell was in the process of reclaiming the state of North Carolina’s voting powers from proxy advisors managing state pension funds. The Top 1000 account reported this was due to Folwell’s “frustration with the rise of shareholders intervening in corporate governance, particularly regarding climate change.”
“We don’t want our proxy to be used to promote policies that don’t have anything to do with our fiduciary responsibility,” said Folwell. “To use these assets and vote these assets in a way that is contrary to our fiduciary responsibilities is not something we are going to do anymore.”^[304]

Opposition to Morningstar ratings of Israel investments (August 2022)

In late August 2022, Folwell and 17 other members of the State Financial Officers Foundation (SFOF) co-signed a letter addressed to the Morningstar investment rating service expressing their “serious concern regarding reports that Morningstar, Inc. (Morningstar), through its wholly-owned subsidiary, Sustainalytics, negatively rates firms connected to Israel in apparent alignment with the Boycott, Divestment, Sanctions (BDS) movement.” The letter asserted the BDS movement was “antithetical to the global causes of peace, democracy, and human rights” and asked Morningstar to take corrective action immediately to terminate all research and ratings products that treat Israel-connected companies differently than companies operating in other free democracies.”^[305]

Support for West Virginia Prohibition of Investments with Firms that Have ESG Bias (August 2022)

Folwell expressed support for West Virginia state treasurer Riley Moore’s (R) decision to prohibit major investment firms engaged in ESG activism from having contracts with his state.
“Treasurer Riley Moore is involved in this because of the nature of his state’s economy,” said Folwell in an August 2022 interview with the Carolina Journal. “He’s not doing this because he can, but because he should.”^[306]
In June 2022, Moore sent letters to BlackRock Inc., Goldman Sachs, JPMorgan Chase, Morgan Stanley, U.S. Bancorp and Wells Fargo, giving each firm 30 days to provide “information demonstrating that it is not engaged in a boycott of energy companies,” and warning that such conduct would render them “ineligible to enter into, or remain in, banking contracts with the State of West Virginia.” Explaining the letters, Moore said West Virginia generated “hundreds of millions of dollars in tax revenue from coal and gas” and that this presented a “clear conflict of interest for financial institutions to handle our dollars that at the same time are trying to diminish our dollars and destroy our industries.”^[307]
Following up in July 2022, Moore announced he would prohibit BlackRock, Goldman Sachs, JPMorgan Chase, Morgan Stanely and Wells Fargo from engaging in banking contracts with any West Virginia state government agency.^[308] A news release from Moore said US Bancorp was not included because it had “eliminated policies against financing coal mining, coal power and pipeline construction activities from its Environmental and Social Risk Policy.”^[309]
According to a Washington Post analysis, firms such as BlackRock and JPMorgan Chase used their “clout to advance causes that are popular among liberals.” Of BlackRock specifically, the report concluded the world’s largest asset manager had “voted against the candidacies of hundreds of corporate board members over their lackluster records on climate issues and called climate change ‘a defining factor in companies’ long-term prospects.’” Likewise, of JPMorgan Chase, the Post noted “the nation’s largest bank” had “stopped lending to new coal mines or coal-fired power plants.”^[310]
A Fox News report said Moore’s action was “a first-of-its-kind response to major banks' ESG push.” Many other state officials responded soon afterward. A New York Times report in August 2022 stated the movement included nearly “two dozen Republican state treasurers” and that treasurers in West Virginia, Arkansas and Louisiana had already pulled a combined $700 million out of BlackRock funds.^[311]^[312]

North Dakota

Thomas Beadle (Treasurer)

As of August 2023, Thomas Beadle (R) is the North Dakota Treasurer. He assumed office on January 1, 2021.

Stances on ESG (click to expand)
As treasurer, Beadle took positions in opposition to environmental, social, and corporate governance (ESG), an approach to investing and corporate decision-making.
State financial officers, including treasurers, auditors, and controllers, are responsible for auditing other government offices, managing payroll, and overseeing pensions. In some states, certain SFOs are also responsible for investing state retirement and trust funds.

West Virginia letter supporting financial system access for fuel industry (November 2021)

Beadle was also a co-signer on a November 22, 2021, letter sent by West Virginia State Treasurer Riley Moore (R) and addressed “To Whom It May Concern in the U.S. Banking Industry.” The signatories were the treasurers, auditors and comptrollers from fifteen states. The letter identified them as the “fiduciaries and stewards of more than $600 billion” in combined investment capital.
The letter began: “We are writing to notify you that we will be taking collective action in response to the ongoing and growing economic boycott of traditional energy production industries by U.S. financial institutions.” The signatories wrote their individual actions would be tailored to fit each state’s unique laws and economic position, but that the coordinated objective would be “to select financial institutions that support a free market and are not engaged in harmful fossil fuel industry boycotts for our states’ financial services contracts.”^[313]

Opposition to U.S. Department of Labor ESG rules (December 2021)

In December 2021, Beadle and 35 other state financial officers and attorneys general submitted a public comment to the U.S. Department of Labor (DOL) in opposition to a proposed DOL rule that would encourage financial managers to consider ESG factors when selecting investments for private sector pension plans.
Titled the “Prudence and Loyalty in Selecting Plan Investments and Exercising Shareholder Rights,” the rule would state that pension plan managers “can make investment decisions that reflect climate change and other environmental, social, or governance (‘ESG’) considerations, including climate-related financial risk, and choose economically targeted investments (‘ETIs’) selected, in part, for benefits apart from the investment return.”
Beadle and the other officials wrote that the rule “would allow employers and investment managers to invest employee retirement savings in a way that benefits social causes and corporate goals even if it adversely affects the return to the employee” and that it would permit “proxy voting in ways that support ESG investment goals contrary to shareholder interests.”
The state officials wrote that they were “opposed to investment managers and employers being encouraged or mandated to consider ESG factors and protected from legal action when they do” and that the DOL’s proposed rule “makes what should be a financial decision into a political one.”^[314]

Letter to John Kerry regarding banking access for energy firms (May 2021)

Beadle was one of fourteen other state treasurers who co-signed a May 2021 letter sent by West Virginia State Treasurer Riley Moore (R) to Special Presidential Envoy for Climate John Kerry (D). The treasurers informed Kerry of their concern that he and others in President Joe Biden’s (D) administration were “privately pressuring U.S. banks and financial institutions to refuse to lend to or invest in coal, oil, and natural gas companies, as part of a misguided strategy to eliminate the fossil fuel industry in our country.” The signatories told Kerry that they “strongly oppose the Biden Administration’s efforts to cut off financing for law-abiding industries that are essential to the economy and our citizens’ way of life.”
According to a March 12, 2021, Politico story referenced in the letter, Kerry was “prodding major U.S. banks privately to announce commitments for climate-friendly finance.” The report also revealed that the Biden administration and several climate policy groups held a March 9, 2022, teleconference to discuss “potential financial sector regulations and executive actions to limit risk from climate change-fueled shocks.” Politico listed representatives from the following groups as participants on the call: the Center for American Progress, Public Citizen, Rainforest Action Network, Sierra Club, and 350.org.^[315]^[316]

Opposition to Federal Reserve Bank appointee (January 2022)

In January 2022, Beadle was one of 25 members of the State Financial Officers Foundation (SFOF) who co-signed a letter to President Joe Biden (D), asking him to withdraw the nomination of Sarah Bloom Raskin to the Federal Reserve Bank Board of Governors.^[79]
In a May 2020 New York Times commentary titled “Why Is the Fed Spending So Much Money on a Dying Industry?,” Raskin wrote that Federal Reserve policy decisions should oppose investments in fossil fuels and support investments in the renewable energy sector: “The decisions the Fed makes on our behalf should build toward a stronger economy with more jobs in innovative industries — not prop up and enrich dying ones.”^[317]
Beadle and the signatories on the SFOF letter wrote that they were concerned Raskin “would use the supervisory authority as Vice-Chair for Supervision at the Federal Reserve Bank to disrupt the private banking sector, reliable energy supplies, and the U.S. economy.”^[79]
In March 2022, Raskin withdrew her name from consideration for the Federal Reserve position.^[318]

Criticism of S&P Ratings (July 2022)

At a July 2022 hearing a panel of the North Dakota Legislative Assembly investigated concerns that financial institutions were using ESG factors in investment decisions targeting states. As a witness before the panel, Beadle told lawmakers that S&P ESG Credit Indicator Report Card had given North Dakota a “neutral” rating for the “social and governance” factors of ESG, and a “moderately negative” rating for the “environmental” factors. The negative assessment, according to Beadle, was because S&P considered the state a “‘climate transition risk’ due to our exposure to oil, gas and coal.”
“It’s easy to see how these type of ratings could get used in years to come to impact businesses operating here and our communities at large,” Beadle told the lawmakers.^[319]

Opposition to Morningstar ratings of Israel investments (August 2022)

In late August 2022, Beadle and 17 other members of the State Financial Officers Foundation (SFOF) co-signed a letter addressed to the Morningstar investment rating service expressing their “serious concern regarding reports that Morningstar, Inc. (Morningstar), through its wholly-owned subsidiary, Sustainalytics, negatively rates firms connected to Israel in apparent alignment with the Boycott, Divestment, Sanctions (BDS) movement.” The letter asserted the BDS movement was “antithetical to the global causes of peace, democracy, and human rights” and asked Morningstar to take corrective action immediately to terminate all research and ratings products that treat Israel-connected companies differently than companies operating in other free democracies.”^[320]

Launch of SFOF “Our Money, Our Values” Website (November 2022)

In November 2022 the State Financial Officers Foundation (SFOF) launched a web portal titled “Our Money, Our Values” to provide tools for taxpayers to “take action” against ESG initiatives by their investment firms and financial advisors. As a member of SFOF, Beadle was contacted by the news site Responsible Investor and asked to comment on the purpose of the new SFOF initiative.^[321]^[322]
“North Dakota is an ag and energy state that helps feed and fuel the world, and we have numerous businesses that have struggled to access capital as a result of these initiatives,” he told Responsible Investor. “People should be informed about where their money is invested in and try to understand the risk/reward involved with those investment decisions.”^[323]

Law enforcement drones

On January 21, 2013, Beadle, fellow Representatives Rick Becker, Dick Anderson, Joe Heilman, Curt Hofstad, David Monson, Karen Rohr, Nathan Toman and Ben Hanson, and Senator Margaret Sitte introduced HB 1373 to restrict the use of unmanned aerial vehicles (drones) by law enforcement agencies. This bill would have required agencies to receive a court warrant for any drone use, and such warrants would have only be obtainable for felony investigations. Exceptions would be made for drones used to patrol the Canadian border, aid law enforcement agencies where there is "reasonable suspicion" that quick action is necessary and evaluate damage during and after natural disasters. HB 1373 would have also allowed people injured by governmental violation of these restrictions to sue the offending law enforcement agencies. The bill would have expressly prohibited surveillance by drones with lethal or non-lethal weapons, private surveillance of other private parties without informed consent and surveillance of people exercising their constitutional rights of free speech and assembly.^[324]^[325] On January 28, the Judiciary Committee held its first hearing on the bill.^[326] The bill passed the House of Representatives on February 22 and was sent to the state Senate. The bill died in the state Senate.^[327]

Ohio

Robert Sprague (Treasurer)

As of August 23, Robert Sprague (R) is the Ohio Treasurer. He assumed office on January 14, 2019.

Stances on ESG (click to expand)
Sprague took positions in opposition to the Environmental, social, and corporate governance (ESG) movement.
State financial officers, including treasurers, auditors, and controllers, are responsible for auditing other government offices, managing payroll, and overseeing pensions. In some states, certain SFOs are also responsible for investing state retirement and trust funds.
In August 2022, Sprague said: “Since taking office in 2019, it has been our mission to be trusted stewards of public dollars and wise investors in Ohio’s future. Adopting ESG-driven investment strategies would run counter to those efforts and undermine the overall financial health of our state.”^[328]

Opposition to Morningstar ratings of Israel investments (August 2022)

In late August 2022, Sprague and 17 other members of the State Financial Officers Foundation (SFOF) co-signed a letter addressed to the Morningstar investment rating service expressing their “serious concern regarding reports that Morningstar, Inc. (Morningstar), through its wholly-owned subsidiary, Sustainalytics, negatively rates firms connected to Israel in apparent alignment with the Boycott, Divestment, Sanctions (BDS) movement.” The letter asserted the BDS movement was “antithetical to the global causes of peace, democracy, and human rights” and asked Morningstar to take corrective action immediately to terminate all research and ratings products that treat Israel-connected companies differently than companies operating in other free democracies.”^[329]
Sprague told the Cleveland Jewish News: “They’re using this BDS criteria. That does nothing more than try to isolate the state of Israel, and continues to spread hatred against the Jewish people. And I think anybody that feels like that is OK needs to understand that America is better than that.”^[330]

Pro-American Energy Letter to President Biden (April 2022)

In April 2022, Sprague and 26 other state financial officers co-signed an open letter to President Joe Biden criticizing his administration for promoting an ESG agenda and enacting policies that “thwart the vitality of American energy production.” The letter specifically criticized Biden for canceling the Keystone XL pipeline, disallowing new oil and natural gas leases on federal lands, canceling drilling projects in Alaska and imposing “anti-oil and gas rulemaking from the highest levels of government.”^[331]
“Instead of asking Americans to purchase electric vehicles—which is simply not an option for a great number of American families—government leaders should eliminate barriers to and expand development of these critical resources, bringing down the price of gas at the pump,” wrote the letter signers. “Most Americans cannot afford to purchase an electric vehicle or equip their home with a full set of solar panels, and many in rural America need traditional fuel to run the trucks that service their farms and help feed their communities.”^[332]
Sprague said: “The answer to America’s energy problem is right beneath our feet. We need to increase domestic energy production and get America back on the path to energy independence.”^[333]

Letter regarding Municipal Securities Rulemaking Board ESG rules (March 2022)

In March 2022, Sprague and 22 other state financial officers cosigned an open letter to the Municipal Securities Rulemaking Board (MSRB) objecting to the board’s decision to issue a “Request for Information on Environmental, Social and Governance (ESG) Practices in the Municipal Securities Market.” In December 2021 the MSRB sent a letter to participants in the municipal securities market, questioning the recipients about their use of ESG criteria and their opinions regarding the propriety of using ESG criteria.^[334]^[335]
“The seemingly innocuous RFI questions are actually precursors to MSRB rules that would require municipalities to make ESG-related disclosures,” wrote the state officers. They accused the MSRB of seeking “information that is useful for one purpose and one purpose alone: transgressing Congress’s ban on requiring disclosures from municipal issuers or regulating their content.”^[336]

Opposition to Federal Reserve Bank appointee (January 2022)

In January 2022, Sprague was one of 25 members of the State Financial Officers Foundation (SFOF) who co-signed a letter to President Joe Biden, asking him to withdraw the nomination of Sarah Bloom Raskin to the Federal Reserve Bank Board of Governors.^[31]
In a May 2020 New York Times commentary titled “Why Is the Fed Spending So Much Money on a Dying Industry?,” Raskin wrote that Federal Reserve policy decisions should favor green energy: “The decisions the Fed makes on our behalf should build toward a stronger economy with more jobs in innovative industries — not prop up and enrich dying ones.”^[337]
Sprague and the signatories on the SFOF letter wrote that they were concerned Raskin “would use the supervisory authority as Vice-Chair for Supervision at the Federal Reserve Bank to disrupt the private banking sector, reliable energy supplies, and the U.S. economy.”^[31]
In March 2022, Raskin withdrew her name from consideration for the Federal Reserve position.^[338]

Letter to John Kerry regarding banking access for energy firms (May 2021)

Sprague was one of fourteen other state treasurers who co-signed a May 2021 letter sent by West Virginia State Treasurer Riley Moore (R) to Special Presidential Envoy for Climate John Kerry (D). The treasurers informed Kerry of their concern that he and others in Joe Biden’s (D) administration were “privately pressuring U.S. banks and financial institutions to refuse to lend to or invest in coal, oil, and natural gas companies, as part of a misguided strategy to eliminate the fossil fuel industry in our country.” The signatories told Kerry that they “strongly oppose the Biden Administration’s efforts to cut off financing for law-abiding industries that are essential to the economy and our citizens’ way of life.”^[94]
According to a March 12, 2021, Politico story referenced in the letter, Kerry was “prodding major U.S. banks privately to announce commitments for climate-friendly finance.” The report also revealed that the Biden administration and several climate policy groups held a March 9, 2022, teleconference to discuss “potential financial sector regulations and executive actions to limit risk from climate change-fueled shocks.” Politico listed representatives from the following groups as participants on the call: the Center for American Progress, Public Citizen, Rainforest Action Network, Sierra Club and 350.org.^[339]^[94]

Oklahoma

Todd Russ (Treasurer)

As of August 2023, Todd Russ (R) is the Oklahoma Treasurer. He assumed office on January 9, 2023.

Stances on ESG (click to expand)
State financial officers, including treasurers, auditors, and controllers, are responsible for auditing other government offices, managing payroll, and overseeing pensions. In some states, certain SFOs are also responsible for investing state retirement and trust funds.

Creation of list of firms with anti-energy policies (February 2023)

In February 2023, Russ announced he had sent questionnaires to banking and financial firms, asking the corporations to explain any ESG policies that applied to oil and natural gas investments. Large asset managers such as BlackRock, Vanguard, and JP Morgan received letters. The questionnaires asked the investment corporations and banks to prove they do not discriminate against energy firms.^[340]^[341]
Oklahoma’s Energy Discrimination Elimination Act of 2022 declares the petroleum and natural gas industry to be a vital state interest. The new state law went into effect in November 2022 and requires all firms wishing to do business with the state to provide proof that they do not engage in discrimination. The law provides firms 60 days to submit proof that they will not boycott the energy industry and stipulates that firms failing to provide documentation will be “presumed to be engaged in discriminating activities.”^[342]^[343]
The law also requires the treasurer to compile a list of the discriminating firms.^[344]^[345]
“I took office on January 9 and began compiling a list of companies, banks, and other entities that act against Oklahoma’s interests because of their ESG stance,” Russ said in a news release. “It is my responsibility to ensure Oklahomans’ tax dollars will not be used to enrich organizations that act counter to our taxpayers’ interests and our values.”^[346]^[347]
“This list is crucial to provide accountability for our government entities, including organizations responsible for pension funds such as the Oklahoma Public Employees Retirement System and Teachers Retirement System,” Russ said. “OPERS alone has more than 60% of their portfolio totaling more than $10 billion managed by BlackRock, a well-known adversary of energy businesses.”^[348]^[349]
Prior to Russ’s announcement, BlackRock, one of the world’s largest asset managers, released a statement claiming it did “not boycott energy companies and will continue to be investors across the energy sector.”^[350]^[351]

Oregon

Tobias Read (Treasurer)

As of August 2023, Tobias Read (D) is the Oregon Treasurer. He assumed office on January 2, 2017.

Stances on ESG (click to expand)
As treasurer, Read expressed support for environmental, social, and corporate governance (ESG), an approach to investing and corporate decision-making.
State financial officers, including treasurers, auditors, and controllers, are responsible for auditing other government offices, managing payroll, and overseeing pensions. In some states, certain SFOs are also responsible for investing state retirement and trust funds.
In a May 2018 newspaper opinion, Read wrote: “Smart investing today means paying closer attention to ESG factors, and with good reason. Research is showing that companies with favorable ESG scores tend to perform better over the long run.”^[352]
"Institutional investors like Oregon benefit from paying attention to everything that can affect the health and long-term sustainability of our investments," Read said in a 2021 interview. "That means looking at climate risks, the diversity of a company's leadership, or how companies treat their employees."^[353]

Hiring of ESG-focused state investment officer (June 2018)

In June 2018, Read announced that he had hired Anna Totdahl as the Oregon State Treasury’s “first-ever investment officer focused on investment risks and opportunities associated with ESG factors.”^[354]

Hosting of ESG investing summit (September 2018)

In September 2018, Read convened the “Oregon Sustainable Investing Summit.” According to a report from the Oregon State Treasury, it was an event where “Read brought together an array of state and national financial leaders to discuss how investors can drive positive investment performance and environmental progress.”
A keynote speaker was Gina McCarthy (D), former administrator of the U.S. Environmental Protection Agency under President Barack Obama (D). Examples of presenters and panelists included representatives from the BlackRock asset management firm, the Sustainability Accounting Standards Board (SASB), and the Service Employees International Union.^[354]
In an October 2021 report to the leadership of the Oregon State Legislature, Read wrote that the purpose of the 2018 event was “to bring together state and national finance leaders to highlight how Oregon Treasury — while first achieving our fiduciary obligation to maximize long-term, risk-adjusted performance — can be a responsible shareholder, engage to enhance climate-related disclosure and action, manage for Environmental, Social, and Governance (ESG) risks, and invest strategically for a cleaner future.”^[355]
“Sustainable investing is the future, and the future can't wait,” Read said, in a news release promoting the event.^[356]

SEC petition seeking mandatory ESG reporting from public firms (October 2018)

In October 2018, Read was a co-signatory on a petition to the Securities and Exchange Commission (SEC) requesting that the federal regulatory agency impose “rulemaking to develop mandatory rules for public companies to disclose high-quality, comparable, decision-useful environmental, social, and governance information.”
The letter acknowledged that “most of America’s largest public companies” were already “attempting to provide additional information” on ESG issues. But the signatories also alleged there were “substantial problems with the nature, timing, and extent of these voluntary disclosures,” and “problems with the quality of voluntary ESG disclosure.”^[357]
The petition was written by Prof. Cynthia A Williams of the Osgoode Hall Law School, and Prof. Jill E Fisch of the University of Pennsylvania Law School. Co-signers included public and private investment officials claiming to represent $5 trillion in assets under management.^[358]

Campaign against JP Morgan Chase board member Lee Raymond (May 2020)

In February 2020, Read and eleven other state treasurers and representatives of state and local public investment funds holding positions in JP Morgan Chase opposed the re-election of Lee Raymond to the board of the publicly-traded banking firm. The CEO of Exxon-Mobil until 2005, Raymond had been on the JP Morgan board for 33 years and was a longtime close ally of JP Morgan Chase CEO Jamie Dimon. Opposition to Raymond’s reappointment was organized by Majority Action, a left-leaning advocacy group, and based on the assertion that Raymond was a “climate change denier” who had influenced JP Morgan Chase to loan too much money to energy firms that produced carbon emitting fuels. The pressure campaign was organized in advance of the JP Morgan Chase annual shareholder meeting, scheduled for May 2020.^[186]^[359]
“As both a fiduciary and a shareholder, Oregon must use our voice and platform to push boards to take action on climate change,” said Read, in a May 2020 statement. “Implementing meaningful strategies that reduce portfolio risk starts at the top. JPMorgan Chase leadership must recognize the significant, far-reaching threats from climate change, and be willing to take necessary steps to reduce those threats.”^[186]
Raymond was ultimately reelected to the board for another term that was scheduled to end in May 2021. However, he announced his resignation in December 2020, to be made effective December 31, 2020. In the regulatory filing announcing the departure, Raymond said it was not as a “result of any disagreement with the company.” Bloomberg News reported that a “spokesman for the bank said Raymond’s retirement has nothing to do with outside pressure.”^[360]^[186]

Increased state pension investment exposure to renewable energy (October 2021)

In an October 2021 report to the leadership of the Oregon State Legislature, Read announced that the Oregon Public Employees Retirement Fund had increased its stake in renewable energy resources firms, from “approximately $50 million in 2014 to in excess of $800 million in 2021.” Read characterized this behavior as an example of the state’s efforts to invest in reaction to the “threats a changing climate brings.”^[361]

Pro-ESG financial officers’ letter opposing anti-ESG state officers (September 2022)

In September 2022, Read and 13 other state and local financial officers co-signed a letter opposing the actions of states that had passed “legislation aiming to curb consideration of environmental, social and governance (ESG) factors in investing.” The letter asserted that “states in our country have started blacklisting financial firms that don’t agree with their political views,” and cited in particular “West Virginia, Idaho, Oklahoma, Texas, and Florida” for “using blacklists to obstruct the free market.”^[50]
According to a September 2022 report from Financial Technologies Forum, Republican elected officials in 24 states had enacted policies against investing public funds with asset management firms such as BlackRock that had used ESG criteria as a basis for investment decisions.^[362]
Read and the signatories alleged the following about the anti-ESG legislation: “The blacklisting states apparently believe, despite ample evidence and scientific consensus to the contrary, that poor working conditions, unfair compensation, discrimination and harassment, and even poor governance practices do not represent material threats to the companies in which they invest. They refuse to acknowledge, in the face of sweltering heat, floods, tornadoes, snowstorms and other extreme weather, that climate change is real and is a true business threat to all of us.”^[50]
“Your job as a state treasurer is to look out for the interest of the beneficiaries. In Oregon's case, it's hundreds of thousands of people, and these are people whose livelihood depends on the pension -- that's what allows them to buy groceries and pay the electric bill and make rent,” said Read, explaining his participation in the letter. “And if you can't separate your own personal politics from your obligation to serve those people, I think you shouldn't be treasurer.”^[363]
In a September 2022 New York Times opinion essay, Read wrote that the anti-ESG efforts represented “something distinctly anti-free market” and “ideological litmus tests that will likely result in lower returns for pensioners.”^[364]

Proposal to achieve “net-zero” pension fund by 2050 (November 2022)

In a November 2022 news release, Read announced a goal for the “Oregon Public Employee Retirement Fund investments to achieve net zero greenhouse gas emissions by no later than 2050, including an interim goal of a 50% decarbonization by 2035.” According to the release, Read pledged to develop a plan to attain the goal and that his plan would be “presented to the OIC [Oregon Investment Council] no later than February 1, 2024.”^[365]
A report in The Oregonian questioned the feasibility of Read’s timeline. According to the report, Read was “just one of five voting members on the Oregon Investment Council, the panel that sets investment policies for a $90 billion pension fund,” and he would “be leaving office at the beginning of 2025” due to term limits.^[366]

Pennsylvania

Stacy Garrity (Treasurer)

As of August 2023, Stacy Garrity (R) is the Pennsylvania Treasurer. She assumed office on January 19, 2021.

Stances on ESG (click to expand)
As treasurer, Garrity took positions in opposition to environmental, social, and corporate governance (ESG), an approach to investing and corporate decision-making.
State financial officers, including treasurers, auditors, and controllers, are responsible for auditing other government offices, managing payroll, and overseeing pensions. In some states, certain SFOs are also responsible for investing state retirement and trust funds.

Letter to John Kerry regarding banking access for energy firms (May 2021)

Garrity was one of fourteen other state treasurers who co-signed a May 2021 letter sent by West Virginia State Treasurer Riley Moore (R) to Special Presidential Envoy for Climate John Kerry (D). The treasurers informed Kerry of their concern that he and others in President Joe Biden’s (D) administration were “privately pressuring U.S. banks and financial institutions to refuse to lend to or invest in coal, oil, and natural gas companies, as part of a misguided strategy to eliminate the fossil fuel industry in our country.” The signatories told Kerry that they “strongly oppose the Biden Administration’s efforts to cut off financing for law-abiding industries that are essential to the economy and our citizens’ way of life.”^[94]
According to a March 12, 2021, Politico story referenced in the letter, Kerry was “prodding major U.S. banks privately to announce commitments for climate-friendly finance.” The report also revealed that the Biden administration and several climate policy groups held a March 9, 2022, teleconference to discuss “potential financial sector regulations and executive actions to limit risk from climate change-fueled shocks.” Politico listed representatives from the following groups as participants on the call: the Center for American Progress, Public Citizen, Rainforest Action Network, Sierra Club and 350.org.^[367]^[94]
Asked to explain her decision to sign the letter, a spokesperson for Garrity said she “is strongly opposed to the Biden administration’s efforts to pressure financial institutions into divesting from coal, oil, and natural gas companies.”^[368]

Use of state law to penalize Ben & Jerry’s for anti-Israel policy (July 2021)

A 2016 Pennsylvania law prohibits the state from contracting with firms that impose economic boycotts against Israel. In July 2021, Garrity announced she supported use of the law against Ben & Jerry’s, after the American ice cream maker announced it was ending sales of its products in the “occupied Palestinian territory.” Then-Israeli Prime Minister Naftali Bennett said the decision had turned Ben & Jerry’s into the “anti-Israel ice cream.”^[369]Cite error: Invalid <ref> tag; invalid names, e.g. too many
“As the General Assembly stated in Act 163 of 2016, Israel is America’s dependable, democratic ally – and it is in the interest of the United States and Pennsylvania to stand with Israel by promoting trade and commerce, and to discourage policies that disregard that interest,” said Garrity. “Treasury will continue to thoroughly review every disbursement to ensure that Act 163 is followed.”
Implementation of Act 163 against Ben & Jerry’s was also supported by future Pennsylvania Gov. Josh Shapiro (D), who was then the Attorney General of Pennsylvania.Cite error: Invalid <ref> tag; invalid names, e.g. too many
Ben & Jerry’s is a subsidiary of Unilever, PLC, a publicly traded multinational consumer products conglomerate.
In June 2022, Unilever announced it was selling the Israeli rights to the ice cream to American Quality Products (AQP), allowing sales to resume in Israel under the new label. In a Twitter statement, Ben & Jerry’s expressed its disagreement with the policy change: “While our parent company has taken this decision, we do not agree with it. Unilever’s arrangement means Ben & Jerry’s in Israel will be owned and operated by AQP. Our company will no longer profit from Ben & Jerry’s in Israel.”^[370]

Opposition to Federal Reserve Bank appointee (January 2022)

In January 2022, Garrity was one of 25 members of the State Financial Officers Foundation (SFOF) who co-signed a letter to President Joe Biden, asking him to withdraw the nomination of Sarah Bloom Raskin to the Federal Reserve Bank Board of Governors.^[79]
In a May 2020 New York Times commentary titled “Why Is the Fed Spending So Much Money on a Dying Industry?,” Raskin wrote that Federal Reserve policy decisions should oppose investments in fossil fuels and support investments in the renewable energy sector: “The decisions the Fed makes on our behalf should build toward a stronger economy with more jobs in innovative industries — not prop up and enrich dying ones.”^[371]
Garrity and the signatories on the SFOF letter wrote that they were concerned Raskin “would use the supervisory authority as Vice-Chair for Supervision at the Federal Reserve Bank to disrupt the private banking sector, reliable energy supplies, and the U.S. economy.”^[79]
“This nominee is a risk to reliable energy companies and the millions of people who are employed by them here in Pennsylvania and across the country,” said Garrity, in a separate news release. “She has claimed that the fossil fuel industry is a ‘dying industry’ and actively worked against it. Meanwhile, the Energy Information Administration’s preliminary data for 2020 shows that energy produced from petroleum, natural gas, and coal accounted for about 79% of total U.S. primary energy production. These energy industries are critical to our nation’s economy, and it’s clear that Ms. Raskin is not the right person to serve in this position. If President Biden doesn’t withdraw the nomination, the Senate should swiftly reject it.”^[372]
In March 2022, Raskin withdrew her name from consideration for the Federal Reserve position.^[373]

Support for lawsuit to keep Pennsylvania out of Regional Greenhouse Gas Initiative (May 2022)

In May 2022, Garrity issued a statement in support of a lawsuit filed by energy firms and labor unions against the Pennsylvania Department of Environmental Protection’s Environmental Quality Board (EQB). The lawsuit was filed to block the implementation of the state’s entry into the Regional Greenhouse Gas Initiative (RGGI).^[374]
The RGGI is an agreement among states in the Eastern United States to cap and reduce carbon emissions. Energy utilities in these states that generate electricity from carbon emitting sources would be required to purchase one carbon allowance for each short ton of carbon they emit. RGGI is a market-adjusted tax whereby the energy firms must bid against each other on the allowances they wish to purchase at quarterly auctions. The number of allowances would be reduced over time, which theoretically incentivizes electricity producers to reduce their carbon emissions or pay steeper prices for fewer allowances made available on the market.^[375]
“RGGI is a massive, illegal tax disguised as a regulation,” Garrity said, according to the news release. “If it’s allowed to be implemented, energy prices for every Pennsylvanian will skyrocket – and thousands of our good, family-sustaining jobs will be lost. The Wolf administration is trying to use the regulatory process to avoid seeking legislative approval for its scheme to impose limits on the operation of electric generators. But our state constitution is clear: The power of taxation belongs to the General Assembly, not to the unelected and unaccountable members of the EQB. I’m proud to stand with our energy companies and the unions who represent many thousands of hardworking Pennsylvanians.”
“The taxes imposed by these unlawful regulations will directly harm miners, electrical workers, welders and fabricators,” Garrity added. “Once lost, these jobs may never return. The Court should act quickly to prevent irreparable harm done to Pennsylvania’s electric generation industry and its thousands of workers.”
The news release also claimed that a Fall 2021 report from the state’s Independent Fiscal Office had shown carbon emissions in Pennsylvania state had fallen by 37% over the prior decade “without the regulatory burden of RGGI.”^[374]

Rhode Island

James Diossa (Treasurer)

As of August 2023, James Diossa (D) is the Rhode Island General Treasurer. He assumed office on January 3, 2023.

Stances on ESG (click to expand)
Diossa took positions in support of the Environmental, social, and corporate governance (ESG) movement.
State financial officers, including treasurers, auditors, and controllers, are responsible for auditing other government offices, managing payroll, and overseeing pensions. In some states, certain SFOs are also responsible for investing state retirement and trust funds.

Campaign statement regarding climate and energy (2022)

On his 2022 campaign website, Diossa said: "It is long past time for us, as a State and as a Nation, to get serious about climate change. The science is real: our world is warming at an alarming rate. Indeed, the speed of global warming has consistently outpaced our predictions. And here in the Ocean State where so many people live by the coast or depend on the ocean for their livelihood, we will be among the first to experience the worst of its effects. As Treasurer, I intend to leverage state funding in order to encourage cities and towns to adopt zoning and land use laws that encourage sustainable energy infrastructure, ensure state-financed construction projects move forward with an eye toward sustainability, and expand funding for green construction projects through the Rhode Island Infrastructure Bank.”^[376]

South Carolina

Richard Eckstrom (Comptroller General)

As of August 2023, Richard Eckstrom (R) was the South Carolina Comptroller General. He assumed office in 2003.

Stances on ESG (click to expand)
As state comptroller general, Eckstrom took positions in opposition to the environmental, social, and corporate governance (ESG) movement.
State financial officers, including treasurers, auditors, and controllers, are responsible for auditing other government offices, managing payroll, and overseeing pensions. In some states, certain SFOs are also responsible for investing state retirement and trust funds.
In May 2022 he said: “My view would be very disapproving of basing investment decisions for investment portfolios on anything other than economic reasons. ESG considerations fall into the political category.”^[377]

Curtis Loftis, Jr. (Treasurer)

As of August 2023, Richard Eckstrom (R) was the South Carolina Comptroller General. He assumed office in 2003.

Stances on ESG (click to expand)
Loftis took positions in opposition to the Environmental, social, and corporate governance (ESG) movement.
State financial officers, including treasurers, auditors, and controllers, are responsible for auditing other government offices, managing payroll, and overseeing pensions. In some states, certain SFOs are also responsible for investing state retirement and trust funds.

Completion of divestment from BlackRock (October 2022)

In October 2022, a news release from the state treasurer’s office on behalf of Loftis announced the divesting of “the final $200 million of BlackRock holdings from a $5 billion portfolio managed by his office, a move that completes a series of actions taken against BlackRock to reduce its impact on the state’s investment portfolios.”^[378]
According to the statement, Loftis began the policy of divesting from BlackRock in 2017 due to the investment management firm’s “focus on promoting progressive Environmental, Social and Governance (ESG) factors as part of its investment strategies.”^[379]
“Five years ago, I realized that ESG had the potential to seriously undermine our state’s economic model from one that values fiduciary responsibility and sound financial judgment to one that pushes the left-wing political agenda of ‘stakeholder capitalism’,” said Loftis, according to the news release. “I have been clear with our financial partners that they will not usurp my fiduciary responsibility to maximize investment returns while accepting a prudent level of risk for the benefit of our citizens. It is imperative that we stand up to BlackRock and others to resist the pressure to adopt their Leftist world view.”^[380]

Opposition to Morningstar ratings of Israel investments (August 2022)

In late August 2022, Loftis and 17 other members of the State Financial Officers Foundation (SFOF) co-signed a letter addressed to the Morningstar investment rating service expressing their “serious concern regarding reports that Morningstar, Inc. (Morningstar), through its wholly-owned subsidiary, Sustainalytics, negatively rates firms connected to Israel in apparent alignment with the Boycott, Divestment, Sanctions (BDS) movement.” The letter asserted the BDS movement was “antithetical to the global causes of peace, democracy, and human rights” and asked Morningstar to take corrective action immediately to terminate all research and ratings products that treat Israel-connected companies differently than companies operating in other free democracies.”^[381]

Opposition to SEC proposal to mandate ESG reporting (June 2022)

In June 2022, Loftis and 22 other state financial officials submitted a comment to the Securities and Exchange Commission (SEC) opposing an SEC rule proposal titled the “Enhancement and Standardization of Climate-Related Disclosures for Investors.” In December 2022, the Pittsburgh Business Times reported that if the SEC rule were finalized it “would become some of the first mandatory environmental, social and governance (ESG) reporting requirements for U.S. companies, requiring the disclosure of climate-related risk information in registration statements and periodic reports.”^[382]^[383]
“We have watched with dismay as the Commission and other federal commissions and boards have proposed rules and policies that promote political causes that will adversely affect public finance and retirement income,” wrote the state financial officers in the letter. “The Proposed Rule is another such rule.” ^[384]
"This is another flagrant attempt by the Biden administration to take power away from the states by circumventing the democratic process and legislating through SEC regulations," said Loftis in a separate statement. "I am committed to working with my fellow state treasurers and auditors to fight the Left's continued push of ESG and their lack of regard for how this will impact our states and citizens."^[385]

Letter to Department of Labor regarding use of ESG criteria in ERISA decisions (May 2022)

In May 2022, Loftis and 37 state officials from 23 states cosigned a letter to the U.S. Department of Labor Employment Benefits Security Administration to oppose the implementation of proposed agency rule. The proposed rule would allow fiduciaries of private pension plans governed by the Employee Retirement Income Security Act (ERISA) to “make investment decisions that reflect climate change and other environmental, social, or governance (“ESG”) considerations, including climate-related financial risk, and choose economically targeted investments (“ETIs”) selected, in part, for benefits apart from the investment return.”^[386]
The cosigners objected to the rule, writing that it “would irrationally require fiduciaries to elevate immaterial and speculative risks in employee retirement savings investment decisions” where instead the fiduciaries should be “considering only the material financial or pecuniary factors of each potential investment.”^[387]

Pro-American Energy Letter to President Biden (April 2022)

In April 2022, Loftis and 26 other state financial officers cosigned an open letter to President Joe Biden criticizing his administration for promoting an ESG agenda and enacting policies that “thwart the vitality of American energy production.” The letter specifically criticized Biden for canceling the Keystone XL pipeline, disallowing new oil and natural gas leases on federal lands, canceling drilling projects in Alaska and imposing “anti-oil and gas rulemaking from the highest levels of government.”^[388]
“Instead of asking Americans to purchase electric vehicles—which is simply not an option for a great number of American families—government leaders should eliminate barriers to and expand development of these critical resources, bringing down the price of gas at the pump,” wrote the letter signers. “Most Americans cannot afford to purchase an electric vehicle or equip their home with a full set of solar panels, and many in rural America need traditional fuel to run the trucks that service their farms and help feed their communities.”^[389]
“We know that rising energy costs are ultimately passed on to American taxpayers, and it’s time that President Biden prioritized the needs and economic interests of American families over special interest groups,” said Loftis, in a separate statement.^[390]

Opposition to Federal Reserve Bank appointee (January 2022)

In January 2022, Loftis was one of 25 members of the State Financial Officers Foundation (SFOF) who co-signed a letter to President Joe Biden (D), asking him to withdraw the nomination of Sarah Bloom Raskin to the Federal Reserve Bank Board of Governors.^[31]
In a May 2020 New York Times commentary titled “Why Is the Fed Spending So Much Money on a Dying Industry?,” Raskin wrote that Federal Reserve policy decisions should be biased against the fossil fuel industry: “The decisions the Fed makes on our behalf should build toward a stronger economy with more jobs in innovative industries — not prop up and enrich dying ones.”^[391]
Loftis and the signatories on the SFOF letter wrote that they were concerned Raskin “would use the supervisory authority as Vice-Chair for Supervision at the Federal Reserve Bank to disrupt the private banking sector, reliable energy supplies, and the U.S. economy.”^[31]
In March 2022, Raskin withdrew her name from consideration for the Federal Reserve position.^[392]

Opposition to U.S. Department of Labor ESG rules (December 2021)

In December 2021, Loftis and 35 other state financial officers and attorneys general submitted a public comment to the U.S. Department of Labor (DOL) in opposition to a proposed DOL rule that would encourage financial managers to consider ESG factors when selecting investments for private sector pension plans.^[393]
Titled the “Prudence and Loyalty in Selecting Plan Investments and Exercising Shareholder Rights,” the rule would state that pension plan managers “can make investment decisions that reflect climate change and other environmental, social, or governance (‘ESG’) considerations, including climate-related financial risk, and choose economically targeted investments (‘ETIs’) selected, in part, for benefits apart from the investment return.”^[394]
Loftis and the other officials wrote that the rule “would allow employers and investment managers to invest employee retirement savings in a way that benefits social causes and corporate goals even if it adversely affects the return to the employee” and that it would permit “proxy voting in ways that support ESG investment goals contrary to shareholder interests.”^[395]
The state officials wrote that they were “opposed to investment managers and employers being encouraged or mandated to consider ESG factors and protected from legal action when they do” and that the DOL’s proposed rule “makes what should be a financial decision into a political one.”^[396]
“This is just another concerning example of how entities pushing liberal agendas are insinuating themselves into financial matters with little regard for the harm these proposals can have on the financial well-being of American citizens,” Loftis said in a separate statement. “We must stand up for the hard-working people who are saving for their retirement and make sure that our federal government doesn’t allow special interests or social causes to undermine citizens’ ability to save for their future livelihood.”^[397]

West Virginia letter supporting financial system access for fuel industry (November 2021)

Loftis was a co-signer on a November 22, 2021, letter sent by West Virginia State Treasurer Riley Moore (R) and addressed: “To Whom It May Concern in the U.S. Banking Industry.” The signatories were the treasurers, auditors and comptrollers from fifteen states. The letter identified them as the “fiduciaries and stewards of more than $600 billion” in combined investment capital.^[398]
The letter began: “We are writing to notify you that we will be taking collective action in response to the ongoing and growing economic boycott of traditional energy production industries by U.S. financial institutions.” The signatories wrote their individual actions would be tailored to fit each state’s unique laws and economic position, but that the coordinated objective would be “to select financial institutions that support a free market and are not engaged in harmful fossil fuel industry boycotts for our states’ financial services contracts.”^[399]

Letter to John Kerry regarding banking access for energy firms (May 2021)

Loftis was one of fourteen other state treasurers who co-signed a May 2021 letter sent by West Virginia State Treasurer Riley Moore (R) to Special Presidential Envoy for Climate John Kerry (D). The treasurers informed Kerry of their concern that he and others in President Joe Biden’s (D) administration were “privately pressuring U.S. banks and financial institutions to refuse to lend to or invest in coal, oil, and natural gas companies, as part of a misguided strategy to eliminate the fossil fuel industry in our country.” The signatories told Kerry that they “strongly oppose the Biden Administration’s efforts to cut off financing for law-abiding industries that are essential to the economy and our citizens’ way of life.”^[94]
According to a March 12, 2021, Politico story referenced in the letter, Kerry was “prodding major U.S. banks privately to announce commitments for climate-friendly finance.” The report also revealed that the Biden administration and several climate policy groups held a March 9, 2022, teleconference to discuss “potential financial sector regulations and executive actions to limit risk from climate change-fueled shocks.” Politico listed representatives from the following groups as participants on the call: the Center for American Progress, Public Citizen, Rainforest Action Network, Sierra Club and 350.org.^[400]^[94]
“As the State’s Banker and Chairman of the State Board of Financial Institutions, I am strongly opposed to President Biden and his Democratic colleagues’ attempt to force their Green New Deal initiatives through Congress,” said Loftis, in a separate statement. “It’s become apparent they don’t have the support needed to succeed, and now they’re trying to bully our financial institutions to enact their radical agenda.”^[401]

South Dakota

Richard Sattgast (Auditor)

As of August 2023, Richard Sattgast (R) is the South Dakota State Auditor. He assumed office on January 7, 2019.

Stances on ESG (click to expand)
Sattgast took positions in opposition to the Environmental, social, and corporate governance (ESG) movement.
State financial officers, including treasurers, auditors, and controllers, are responsible for auditing other government offices, managing payroll, and overseeing pensions. In some states, certain SFOs are also responsible for investing state retirement and trust funds.

Pro-American Energy Letter to President Biden (April 2022)

In April 2022, Sattgast and 26 other state financial officers cosigned an open letter to President Joe Biden (D) criticizing his administration for promoting an ESG agenda and enacting policies that “thwart the vitality of American energy production.” The letter specifically criticized Biden for canceling the Keystone XL pipeline, disallowing new oil and natural gas leases on federal lands, canceling drilling projects in Alaska and imposing “anti-oil and gas rulemaking from the highest levels of government.”^[402]
“Instead of asking Americans to purchase electric vehicles—which is simply not an option for a great number of American families—government leaders should eliminate barriers to and expand development of these critical resources, bringing down the price of gas at the pump,” wrote the letter signers. “Most Americans cannot afford to purchase an electric vehicle or equip their home with a full set of solar panels, and many in rural America need traditional fuel to run the trucks that service their farms and help feed their communities.”^[403]

Josh Haeder (Treasure)

As of August 2023, Josh Haeder (R) is the South Dakota Treasurer. He assumed office on January 7, 2019.

Stances on ESG (click to expand)
Header has taken positions in opposition to the Environmental, social, and corporate governance (ESG) movement.

Opposition to SEC proposal to mandate ESG reporting (June 2022)

In June 2022, Haeder and 22 other state financial officials submitted a comment to the Securities and Exchange Commission (SEC) opposing an SEC rule proposal titled the “Enhancement and Standardization of Climate-Related Disclosures for Investors.” In December 2022, the Pittsburgh Business Times reported that if the SEC rule were finalized it “would become some of the first mandatory environmental, social and governance (ESG) reporting requirements for U.S. companies, requiring the disclosure of climate-related risk information in registration statements and periodic reports.”^[404]^[405]
“We have watched with dismay as the Commission and other federal commissions and boards have proposed rules and policies that promote political causes that will adversely affect public finance and retirement income,” wrote the state financial officers in the letter. “The Proposed Rule is another such rule.”^[406]

Opposition to Morningstar ratings of Israel investments (August 2022)

In late August 2022, Haeder and 17 other members of the State Financial Officers Foundation (SFOF) co-signed a letter addressed to the Morningstar investment rating service expressing their “serious concern regarding reports that Morningstar, Inc. (Morningstar), through its wholly-owned subsidiary, Sustainalytics, negatively rates firms connected to Israel in apparent alignment with the Boycott, Divestment, Sanctions (BDS) movement.” The letter asserted the BDS movement was “antithetical to the global causes of peace, democracy, and human rights” and asked Morningstar to take corrective action immediately to terminate all research and ratings products that treat Israel-connected companies differently than companies operating in other free democracies.”^[407]

Pro-American Energy Letter to President Biden (April 2022)

In April 2022, Haeder and 26 other state financial officers cosigned an open letter to President Joe Biden criticizing his administration for promoting an ESG agenda and enacting policies that “thwart the vitality of American energy production.” The letter specifically criticized Biden for canceling the Keystone XL pipeline, disallowing new oil and natural gas leases on federal lands, canceling drilling projects in Alaska and imposing “anti-oil and gas rulemaking from the highest levels of government.”^[408]
“Instead of asking Americans to purchase electric vehicles—which is simply not an option for a great number of American families—government leaders should eliminate barriers to and expand development of these critical resources, bringing down the price of gas at the pump,” wrote the letter signers. “Most Americans cannot afford to purchase an electric vehicle or equip their home with a full set of solar panels, and many in rural America need traditional fuel to run the trucks that service their farms and help feed their communities.”^[409]

Texas

Glenn Hegar (Comptroller of Public Accounts)

As of August 2023, Glenn Hegar (R) is the Texas Comptroller of Public Accounts. He assumed office on January 1, 2015.

Stances on ESG (click to expand)

As comptroller, Hegar took positions in opposition to environmental, social, and corporate governance (ESG), an approach to investing and corporate decision-making.

State financial officers, including treasurers, auditors, and controllers, are responsible for auditing other government offices, managing payroll, and overseeing pensions. In some states, certain SFOs are also responsible for investing state retirement and trust funds.

“Numerous companies and their leadership are pushing an environmental and social agenda that not only threatens the Texas economy and jobs, but also undermines national security,” Hegar said in March 2022.^[410]

Divesting state funds from Ben & Jerry’s (September 2021)

In July 2021, American ice cream maker Ben & Jerry’s announced it was ending sales of its products in the “occupied Palestinian territory.” In response, Israeli Prime Minister Naftali Bennett said Ben & Jerry’s had become the “anti-Israel ice cream.”^[411]

Ben & Jerry’s is a subsidiary of Unilever, PLC, a publicly traded multinational consumer products conglomerate. Texas law prohibits the state from holding investments in firms that are found to have boycotted Israel.^[412]

On September 23, 2021, Hegar added Ben & Jerry’s and Unilever to the state’s list of firms boycotting Israel. According to a statement from his office, the “action was undertaken pursuant to Texas Government Code Chapter 808, which defines “boycott Israel” as “refusing to deal with, terminating business activities with, or otherwise taking any action that is intended to penalize, inflict economic harm on or limit commercial relations specifically with Israel or with a person or entity doing business in Israel or in an Israeli-controlled territory...”^[413]

In June 2022, Unilever announced it was selling the Israeli rights to the ice cream to American Quality Products (AQP), allowing sales to resume in Israel under the new label. In a Twitter statement, Ben & Jerry’s expressed its disagreement with the policy change:

“

“While our parent company has taken this decision, we do not agree with it. Unilever’s arrangement means Ben & Jerry’s in Israel will be owned and operated by AQP. Our company will no longer profit from Ben & Jerry’s in Israel.”^[414]^[13]

”

West Virginia letter supporting financial system access for fuel industry (November 2021)

Hegar was a co-signer on a November 22, 2021, letter sent by West Virginia State Treasurer Riley Moore (R) and addressed: “To Whom It May Concern in the U.S. Banking Industry.” The signatories were the treasurers, auditors and comptrollers from fifteen states. The letter identified them as the “fiduciaries and stewards of more than $600 billion” in combined investment capital.

The letter began: “We are writing to notify you that we will be taking collective action in response to the ongoing and growing economic boycott of traditional energy production industries by U.S. financial institutions.” The signatories wrote their individual actions would be tailored to fit each state’s unique laws and economic position, but that the coordinated objective would be “to select financial institutions that support a free market and are not engaged in harmful fossil fuel industry boycotts for our states’ financial services contracts.”^[415]

Investment firms found in violation of Texas energy boycott law (August 2022)

A 2021 Texas law prohibits state pension funds and retirement funds from investing in financial firms found to be boycotting energy companies. The law also requires the Texas Comptroller of Public Accounts to research and compile a list of such firms.^[416]^[417]

On August 24, 2022, Hegar announced that ten financial firms had ESG investment policies that were not compliant with the Texas anti-boycott law: BlackRock, BNP Paribas SA, Credit Suisse, Danske Bank, Jupiter Fund Management PLC, Nordea Bank ABP, Schoders PLC, Svenska Handelsbanken AB, Swedbank AB, and UBS Group AG. Hegar placed all ten on the list of firms prohibited from managing state investments.

“The environmental, social and corporate governance (ESG) movement has produced an opaque and perverse system in which some financial companies no longer make decisions in the best interest of their shareholders or their clients, but instead use their financial clout to push a social and political agenda shrouded in secrecy,” Hegar said, according to an August 2022 news release announcing public release of the list.^[418]

Utah

Marlo Oaks (Treasurer)

As of August 2023, Marlo Oaks (R) is the Utah Treasurer. He assumed office on July 20, 2021.

Stances on ESG (click to expand)
As treasurer, Oaks took positions in opposition to environmental, social, and corporate governance (ESG), an approach to investing and corporate decision-making. ^[419]
State financial officers, including treasurers, auditors, and controllers, are responsible for auditing other government offices, managing payroll, and overseeing pensions. In some states, certain SFOs are also responsible for investing state retirement and trust funds.
In April 2022, he said ESG was “about controlling and forcing behaviors” and an effort “to do through capital markets what activists and their government allies have been unable to do through democratic processes.”^[94]

West Virginia letter supporting financial system access for fuel industry (November 2021)

Oakes was a co-signer on a November 22, 2021, letter sent by West Virginia State Treasurer Riley Moore (R) and addressed: “To Whom It May Concern in the U.S. Banking Industry.” The signatories were the treasurers, auditors and comptrollers from fifteen states. The letter identified them as the “fiduciaries and stewards of more than $600 billion” in combined investment capital.
The letter began: “We are writing to notify you that we will be taking collective action in response to the ongoing and growing economic boycott of traditional energy production industries by U.S. financial institutions.” The signatories wrote their individual actions would be tailored to fit each state’s unique laws and economic position, but that the coordinated objective would be “to select financial institutions that support a free market and are not engaged in harmful fossil fuel industry boycotts for our states’ financial services contracts.”^[420]
“Traditional energy plays an important role in Utah’s economy, particularly in rural Utah,” said Oaks. “Cutting off financing for businesses engaged in economically essential activities to advance a radical social agenda destroys livelihoods, increases costs and does little to advance the desire we all have to breathe cleaner air and improve the environment.”^[421]

Opposition to U.S. Department of Labor ESG rules (December 2021)

See also: Opposition to environmental, social, and corporate governance (ESG) investing

In December 2021, Oaks and 35 other state financial officers and attorneys general submitted a public comment to the U.S. Department of Labor (DOL) in opposition to a proposed DOL rule that would encourage financial managers to consider ESG factors when selecting investments for private sector pension plans.^[422]
Titled the “Prudence and Loyalty in Selecting Plan Investments and Exercising Shareholder Rights,” the rule would state that pension plan managers “can make investment decisions that reflect climate change and other environmental, social, or governance (‘ESG’) considerations, including climate-related financial risk, and choose economically targeted investments (‘ETIs’) selected, in part, for benefits apart from the investment return.”^[422]
Oaks and the other officials wrote that the rule “would allow employers and investment managers to invest employee retirement savings in a way that benefits social causes and corporate goals even if it adversely affects the return to the employee” and that it would permit “proxy voting in ways that support ESG investment goals contrary to shareholder interests.”^[422]
The state officials wrote that they were “opposed to investment managers and employers being encouraged or mandated to consider ESG factors and protected from legal action when they do” and that the DOL’s proposed rule “makes what should be a financial decision into a political one.”^[422]
“The proposed rule would politicize retirement savings plans rather than preserve the fiduciary loyalty owed to plan participants who are counting on financial returns to fund their retirement,” said Oaks in a news release regarding the letter. ^[423]

Opposition to Federal Reserve Bank appointee (January 2022)

In January 2022, Oaks was one of 25 members of the State Financial Officers Foundation (SFOF) who co-signed a letter to President Joe Biden, asking him to withdraw the nomination of Sarah Bloom Raskin to the Federal Reserve Bank Board of Governors.^[15]
In a May 2020 New York Times commentary titled “Why Is the Fed Spending So Much Money on a Dying Industry?” Raskin wrote that Federal Reserve policy decisions should oppose investments in fossil fuels and support investments in the renewable energy sector: “The decisions the Fed makes on our behalf should build toward a stronger economy with more jobs in innovative industries — not prop up and enrich dying ones.”^[424]
Oaks and the signatories on the SFOF letter wrote that they were concerned Raskin “would use the supervisory authority as Vice-Chair for Supervision at the Federal Reserve Bank to disrupt the private banking sector, reliable energy supplies, and the U.S. economy.”^[15]
In March 2022, Raskin withdrew her name from consideration for the Federal Reserve position.^[425]

Letter regarding use of ESG criteria by S&P Global Ratings (April 2022)

In April 2022, Oaks and Utah Attorney General Sean Reyes (R) organized a letter sent “on behalf of the State of Utah” to the leadership of S&P Global Ratings, opposing the firm’s policy of publishing “ESG credit indicators as part of its credit ratings for states and state subdivisions.” The letter was co-signed by Utah Gov. Spencer Cox, the leadership of both the Utah House and Senate, and the entire Utah Congressional delegation.^[426]^[94]
In a statement regarding the letter, Oaks said S&P’s policy represented “a political score that, intentionally or not, can result in market participants using economic force to drive a political agenda” and that the “focus on ESG when evaluating state and local governments threatens to obscure real investment risks, undermine faith in the impartiality of credit ratings, and penalize states whose politics do not align with the political interests behind the ratings system.”^[94]^[427]

John Dougall (Auditor)

John Dougall (Republican Party) (also known as Frugal) was the Utah State Auditor. He assumed office on January 7, 2013. He left office on January 6, 2025.

Dougall (Republican Party) ran for election to the U.S. House to represent Utah's 3rd Congressional District. He lost in the Republican primary on June 25, 2024.

Dougall completed Ballotpedia's Candidate Connection survey in 2024. Click here to read the survey answers.

Stances on ESG (click to expand)
As auditor, Dougall took positions in opposition to environmental, social, and corporate governance (ESG), an approach to investing and corporate decision-making.
State financial officers, including treasurers, auditors, and controllers, are responsible for auditing other government offices, managing payroll, and overseeing pensions. In some states, certain SFOs are also responsible for investing state retirement and trust funds.

West Virginia letter supporting financial system access for fuel industry (November 2021)

Dougall was a co-signer on a November 22, 2021, letter sent by West Virginia State Treasurer Riley Moore (R) and addressed: “To Whom It May Concern in the U.S. Banking Industry.” The signatories were the treasurers, auditors and comptrollers from fifteen states. The letter identified them as the “fiduciaries and stewards of more than $600 billion” in combined investment capital.
The letter began: “We are writing to notify you that we will be taking collective action in response to the ongoing and growing economic boycott of traditional energy production industries by U.S. financial institutions.” The signatories wrote their individual actions would be tailored to fit each state’s unique laws and economic position, but that the coordinated objective would be “to select financial institutions that support a free market and are not engaged in harmful fossil fuel industry boycotts for our states’ financial services contracts.”^[428]
“Banks and investors should focus on the potential of companies to provide increased shareholder value, rather than favoring certain partisan agendas, particularly at the expense of shareholders,” said Dougall. “Energy companies of all types should have unfettered access to capital and lending markets.”^[429]

Opposition to U.S. Department of Labor ESG rules (December 2021)

In December 2021, Dougall and 35 other state financial officers and attorneys general submitted a public comment to the U.S. Department of Labor (DOL) in opposition to a proposed rule that would encourage financial managers to consider ESG factors when selecting investments for private sector pension plans.^[422]
Titled the “Prudence and Loyalty in Selecting Plan Investments and Exercising Shareholder Rights,” the rule would state that pension plan managers “can make investment decisions that reflect climate change and other environmental, social, or governance (‘ESG’) considerations, including climate-related financial risk, and choose economically targeted investments (‘ETIs’) selected, in part, for benefits apart from the investment return.”^[422]
Dougall and the other officials wrote that the rule “would allow employers and investment managers to invest employee retirement savings in a way that benefits social causes and corporate goals even if it adversely affects the return to the employee” and that it would permit “proxy voting in ways that support ESG investment goals contrary to shareholder interests.”^[422]
The state officials wrote that they were “opposed to investment managers and employers being encouraged or mandated to consider ESG factors and protected from legal action when they do” and that the DOL’s proposed rule “makes what should be a financial decision into a political one.”^[422]
“These social agendas too often financially disenfranchise business owners and weaken management’s duty to act in the best interest of all shareholders,” said Dougall in a news release regarding the letter.^[430]

Opposition to Federal Reserve Bank appointee (January 2022)

In January 2022, Dougall was one of 25 members of the State Financial Officers Foundation (SFOF) who co-signed a letter to President Joe Biden, asking him to withdraw the nomination of Sarah Bloom Raskin to the Federal Reserve Bank Board of Governors.^[31]
In a May 2020 New York Times commentary titled “Why Is the Fed Spending So Much Money on a Dying Industry?” Raskin wrote that Federal Reserve policy decisions should be biased against the fossil fuel industry: “The decisions the Fed makes on our behalf should build toward a stronger economy with more jobs in innovative industries — not prop up and enrich dying ones.”^[431]
Dougall and the signatories on the SFOF letter wrote that they were concerned Raskin “would use the supervisory authority as Vice-Chair for Supervision at the Federal Reserve Bank to disrupt the private banking sector, reliable energy supplies, and the U.S. economy.”^[31]
In March 2022, Raskin withdrew her name from consideration for the Federal Reserve position.^[432]

Letter regarding use of ESG criteria by S&P Global Ratings (April 2022)

In April 2022, Dougall co-signed a letter sent “on behalf of the State of Utah” to the leadership of S&P Global Ratings, opposing the firm’s policy of publishing “ESG credit indicators as part of its credit ratings for states and state subdivisions.” The letter was organized by Utah Treasurer Marlo Oaks and Utah Attorney General Sean Reyes, and also co-signed by Utah Gov. Spencer Cox (R), the leadership of both the Utah House and Senate, and the entire Utah Congressional delegation.^[433]^[434]

Opposition to Morningstar ratings of Israel investments (August 2022)

In late August 2022, Dougall and 17 other members of the State Financial Officers Foundation (SFOF) co-signed a letter addressed to the Morningstar investment rating service expressing their “serious concern regarding reports that Morningstar, Inc. (Morningstar), through its wholly-owned subsidiary, Sustainalytics, negatively rates firms connected to Israel in apparent alignment with the Boycott, Divestment, Sanctions (BDS) movement.” The letter asserted the BDS movement was “antithetical to the global causes of peace, democracy, and human rights” and asked Morningstar to take corrective action immediately to terminate all research and ratings products that treat Israel-connected companies differently than companies operating in other free democracies.”^[435]

Vermont

Michael Pieciak (Treasurer)

As of August 2023, Michael Pieciak (D) is the Vermont Treasurer. He assumed office on January 5, 2023.

Stances on ESG (click to expand)
Pieciak took positions in support of the Environmental, social, and corporate governance (ESG) movement.
State financial officers, including treasurers, auditors, and controllers, are responsible for auditing other government offices, managing payroll, and overseeing pensions. In some states, certain SFOs are also responsible for investing state retirement and trust funds.
In 2017, the Vermont Treasurer’s office and the Vermont Pension Investment Committee (VPIC) adopted a policy requiring the state to weigh ESG factors when evaluating investment risks and opportunities.^[436]^[437]
Pieciak’s 2022 campaign website identified climate change as “a fundamental threat to our way of life and economy,” including “Vermont’s traditional industries—such as maple sugaring, foliage tourism, ski season, and agriculture.” Pieciak promoted ESG policies like requiring publicly-traded firms to disclose their carbon impact and divesting state investments from positions in fossil fuel energy companies as part of his campaign.^[438]

Washington

Mike Pellicciotti (Treasurer)

As of August 2023, Mike Pellicciotti (D) is the Washington Treasurer. He assumed office on January 11, 2021.

Stances on ESG (click to expand)
Pellicciotti supported environmental, social, and corporate governance (ESG), an approach to investing and corporate decision-making.
State financial officers, including treasurers, auditors, and controllers, are responsible for auditing other government offices, managing payroll, and overseeing pensions. In some states, certain SFOs are also responsible for investing state retirement and trust funds.
In July 2021, Pellicciotti wrote, “I believe we must always look at the long term risks to our investments. That’s why in my first few months as State Treasurer, I completed an environmental, social and corporate governance review of all state investments over which I have direct control – and I am proud to say my office does not invest in any coal, oil or gas companies. This action is consistent with my view that ownership of corporate debt or stock in these companies is not a prudent long-term investment for our state.”^[439]

Support for ESG board seats at Exxon-Mobil (June 2021)

In June 2021, the Washington State Investment Board (WSIB) sided with a group of activist shareholders who successfully replaced three members of the ExxonMobil energy board. The Washington Treasurer is one of ten voting members on the WSIB. Pellicciotti wrote, "This vote contributed to the removal of current corporate Board leaders of ExxonMobil up for reelection, replacing them with climate conscious directors who will support long-term investment interests. Washington voted for a reform slate of candidates to move ExxonMobil away from its focus on short-term fossil fuel profits.”^[440]
The hedge fund Engine No. 1 launched the election campaign for the new board members, writing in a pitch to investors that ExxonMobil's "refusal to accept that fossil fuel demand may decline in decades to come has led to a failure to take even initial steps towards evolution."^[441] Engine No. 1 won support for its position from large money management firms BlackRock, Vanguard and State Street Global Advisors.^[442]

Pro-ESG financial officers’ letter opposing anti-ESG state officers (September 2022)

In September 2022, Pellicciotti and 13 other state and local financial officers signed a letter opposing laws and policies in West Virginia, Idaho, Oklahoma, Texas, and Florida "aiming to curb consideration of environmental, social and governance (ESG) factors in investing."^[50]
The letter said those states were "blacklisting financial firms that don’t agree with their political views." The letter also said, “the blacklisting states apparently believe, despite ample evidence and scientific consensus to the contrary, that poor working conditions, unfair compensation, discrimination and harassment, and even poor governance practices do not represent material threats to the companies in which they invest. They refuse to acknowledge, in the face of sweltering heat, floods, tornadoes, snowstorms and other extreme weather, that climate change is real and is a true business threat to all of us.”^[50]

West Virginia

Riley Moore (Treasurer)

As of August 2023, Michael Pieciak (D) is the Vermont Treasurer. He assumed office on January 5, 2023.

Stances on ESG (click to expand)
As treasurer, Moore took positions in opposition to environmental, social, and corporate governance (ESG), an approach to investing and corporate decision-making.^[443]
State financial officers, including treasurers, auditors, and controllers, are responsible for auditing other government offices, managing payroll, and overseeing pensions. In some states, certain SFOs are also responsible for investing state retirement and trust funds.

Letter to John Kerry regarding banking access for energy firms (May 2021)

In a May 2021 letter to Special Presidential Envoy for Climate John Kerry, Moore wrote that he was concerned that Kerry and others in President Joe Biden’s (D) administration were “privately pressuring U.S. banks and financial institutions to refuse to lend to or invest in coal, oil, and natural gas companies, as part of a misguided strategy to eliminate the fossil fuel industry in our country.” The letter was co-signed by state treasurers in fourteen other states, and informed Kerry that the signatories “strongly oppose the Biden Administration’s efforts to cut off financing for law-abiding industries that are essential to the economy and our citizens’ way of life”^[444]
According to a March 12, 2021, Politico story referenced in the letter, Kerry was “prodding major U.S. banks privately to announce commitments for climate-friendly finance.” The report also revealed that the Biden administration and several climate policy groups held a March 9, 2022, teleconference to discuss “potential financial sector regulations and executive actions to limit risk from climate change-fueled shocks.” Politico listed representatives from the following groups as participants on the call: the Center for American Progress, Public Citizen, Rainforest Action Network, Sierra Club, and 350.org. ^[445]^[446]

West Virginia letter supporting financial system access for fuel industry (November 2021)

On November 22, 2021, Moore released an open letter addressed: “To Whom It May Concern in the U.S. Banking Industry.” The letter was co-signed by the top financial officials from fifteen states, who were identified as the “fiduciaries and stewards of more than $600 billion” in combined investment capital.
The letter began: “We are writing to notify you that we will be taking collective action in response to the ongoing and growing economic boycott of traditional energy production industries by U.S. financial institutions.” The signatories wrote their individual actions would be tailored to fit each state’s unique laws and economic position, but that the coordinated objective would be “to select financial institutions that support a free market and are not engaged in harmful fossil fuel industry boycotts for our states’ financial services contracts.”^[447]

Letter to Unilever CEO regarding Ben & Jerry’s anti-Israel policy (December 2021)

In July 2021, American ice cream maker Ben & Jerry’s announced it was ending sales of its products in the “occupied Palestinian territory.” In response, Israeli Prime Minister Naftali Bennett said Ben & Jerry’s had become the “anti-Israel ice cream.”^[448]
Ben & Jerry’s is a subsidiary of Unilever, PLC, a publicly traded multinational consumer products conglomerate.
On December 9, 2021, Moore was one of six other state treasurers co-signing a letter sent by Arizona State Treasurer Kimberly Yee to Unilever CEO Alan Jope, accusing him of attempting to “deflect responsibility for Ben & Jerry’s boycott by suggesting that you have no authority over your subsidiary’s decision in this case.” The letter cited two law professors who had reviewed the Ben & Jerry’s acquisition agreement and found that it required Ben & Jerry’s to “help Unilever sell the premium ice cream in Israel.” The treasurers asked Jope to provide “full clarification and transparency regarding Unilever’s ability to override the discriminatory boycott of Israel initiated by Ben & Jerry’s.”^[449]
In June 2022, Unilever announced it was selling the Israeli rights to the ice cream to American Quality Products (AQP), allowing sales to resume in Israel under the new label. In a Twitter statement, Ben & Jerry’s expressed its disagreement with the policy change:
“While our parent company has taken this decision, we do not agree with it. Unilever’s arrangement means Ben & Jerry’s in Israel will be owned and operated by AQP. Our company will no longer profit from Ben & Jerry’s in Israel.”^[450]

Opposition to Federal Reserve Bank appointee (January 2022)

In January 2022, Moore was one of 25 members of the State Financial Officers Foundation (SFOF) who co-signed a letter to President Joe Biden (D), asking him to withdraw the nomination of Sarah Bloom Raskin to the Federal Reserve Bank Board of Governors.^[15]
In a May 2020 New York Times commentary titled “Why Is the Fed Spending So Much Money on a Dying Industry?,” Raskin wrote that Federal Reserve policy decisions should oppose investments in fossil fuels and support investments in the renewable energy sector: “The decisions the Fed makes on our behalf should build toward a stronger economy with more jobs in innovative industries — not prop up and enrich dying ones.”^[451]
Moore and the signatories on the SFOF letter wrote that they were concerned Raskin “would use the supervisory authority as Vice-Chair for Supervision at the Federal Reserve Bank to disrupt the private banking sector, reliable energy supplies, and the U.S. economy.”^[15]
In March 2022, Raskin withdrew her name from consideration for the Federal Reserve position.^[452]

Prohibition of investments with financial firms that have anti-energy bias (July 2022)

In June 2022, Moore sent letters to BlackRock Inc., Goldman Sachs, JPMorgan Chase, Morgan Stanley, U.S. Bancorp and Wells Fargo, giving each firm 30 days to provide “information demonstrating that it is not engaged in a boycott of energy companies,” and warning that such conduct would render them “ineligible to enter into, or remain in, banking contracts with the State of West Virginia.” Explaining the letters, Moore said West Virginia generated “hundreds of millions of dollars in tax revenue from coal and gas” and that this presented a “clear conflict of interest for financial institutions to handle our dollars that at the same time are trying to diminish our dollars and destroy our industries.”^[453]
Following up in July 2022, Moore announced he would prohibit BlackRock, Goldman Sachs, JPMorgan Chase, Morgan Stanely and Wells Fargo from engaging in banking contracts with any West Virginia state government agency.^[454] A news release from Moore said US Bancorp was not included because it had “eliminated policies against financing coal mining, coal power and pipeline construction activities from its Environmental and Social Risk Policy.”^[455]
A Washington Post analysis stated that firms such as BlackRock and JPMorgan Chase had used their “clout to advance causes that are popular among liberals.” Of BlackRock specifically, the report concluded the world’s largest asset manager had “voted against the candidacies of hundreds of corporate board members over their lackluster records on climate issues and called climate change 'a defining factor in companies’ long-term prospects.'” Likewise, of JPMorgan Chase, the Post noted “the nation’s largest bank” had “stopped lending to new coal mines or coal-fired power plants.”^[456]
A Fox News report said Moore’s action was “a first-of-its-kind response to major banks' ESG push.” Many other state officials responded soon afterward. A New York Times report in August 2022 stated the movement included nearly “two dozen Republican state treasurers” and that treasurers in West Virginia, Arkansas and Louisiana had already pulled a combined $700 million out of BlackRock funds.^[457]^[458]

Opposition to Morningstar ratings of Israel investments (August 2022)

In late August 2022, Moore and 17 other members of the State Financial Officers Foundation (SFOF) co-signed a letter addressed to the Morningstar investment rating service expressing their “serious concern regarding reports that Morningstar, Inc. (Morningstar), through its wholly-owned subsidiary, Sustainalytics, negatively rates firms connected to Israel in apparent alignment with the Boycott, Divestment, Sanctions (BDS) movement.” The letter asserted the BDS movement was “antithetical to the global causes of peace, democracy, and human rights” and asked Morningstar to take corrective action immediately to terminate all research and ratings products that treat Israel-connected companies differently than companies operating in other free democracies.”^[459]

John B. McCuskey (Auditor)

As of August 2023, John B. McCuskey (R) (also known as JB) is the West Virginia State Auditor. He assumed office on January 16, 2017.

Stances on ESG (click to expand)
As auditor, McCuskey took positions in opposition to environmental, social, and corporate governance (ESG), an approach to investing and corporate decision-making.
State financial officers, including treasurers, auditors, and controllers, are responsible for auditing other government offices, managing payroll, and overseeing pensions. In some states, certain SFOs are also responsible for investing state retirement and trust funds.

Opposition to SEC proposal to mandate ESG reporting (June 2022)

In June 2022, McCuskey and Mississippi Secretary of State Michael Watson (R) submitted a comment to the Securities and Exchange Commission (SEC) opposing a rule proposal titled the “Enhancement and Standardization of Climate-Related Disclosures for Investors.” The Pittsburgh Business Times reported the SEC rule “would become some of the first mandatory environmental, social and governance (ESG) reporting requirements for U.S. companies, requiring the disclosure of climate-related risk information in registration statements and periodic reports.”^[460]^[461]
McCuskey and Watson wrote: “The proposal goes beyond the scope of a disclosure framework to advance substantive social policy positions that exceed and are outside the legislative authority granted to the Securities and Exchange Commission.”^[462]
McCuskey wrote in a separate news release that "the proposed rule by the SEC will unnecessarily politicize this agency, erode public confidence in the institution and will ultimately result in the creation of an impotent enforcement agency that is used as a political football by whomever is in power.”^[462]

Wisconsin

John Leiber (Treasurer)

As of August 2023, John Leiber (R) is the Wisconsin Treasurer. He assumed office on January 2, 2023.

Stances on ESG (click to expand)
Leiber took positions in opposition to the Environmental, social, and corporate governance (ESG) movement.
State financial officers, including treasurers, auditors, and controllers, are responsible for auditing other government offices, managing payroll, and overseeing pensions. In some states, certain SFOs are also responsible for investing state retirement and trust funds.
Leiber’s immediate predecessor, Wisconsin Secretary of State Sarah Godlewski (D), made ESG issues a priority while she was the state treasurer. Godlewski's 2022 campaign website said: “[as] Wisconsin State Treasurer, Sarah’s first major act was to overturn a Republican gag order that prevented climate change from being considered when making investments.” Aaron Richardson (D), the candidate Leiber defeated in the 2022 race for state treasurer, had pledged to continue Godlewski’s ESG priorities.^[463]^[464]
Shortly before taking office as treasurer, Leiber said: “I don't think we should be trying to tailor our investments to fit some political goal. I think we should be looking at maximizing the returns on the investment because that's what benefits the people of Wisconsin.”^[465]
A Milwaukee Journal-Sentinel analysis of Leiber reported that this position put him “at a stark contrast to Democrats who have called on the treasurer to take up a more active role in rolling out social programs and investing in green energy and climate resiliency initiatives.”^[466]

Wyoming

Curt Meier (Treasurer)

As of August 2023, Curt Meier (R) is the Wyoming Treasurer. He assumed office on January 7, 2019.

Stances on ESG (click to expand)
As treasurer, Meier took positions in opposition to environmental, social, and corporate governance (ESG), an approach to investing and corporate decision-making.
State financial officers, including treasurers, auditors, and controllers, are responsible for auditing other government offices, managing payroll, and overseeing pensions. In some states, certain SFOs are also responsible for investing state retirement and trust funds.

West Virginia letter supporting financial system access for fuel industry (November 2021)

Meier was also a co-signer on a November 22, 2021, letter sent by West Virginia State Treasurer Riley Moore (R) and addressed: “To Whom It May Concern in the U.S. Banking Industry.” The signatories were the treasurers, auditors, and comptrollers from fifteen states. The letter identified them as the “fiduciaries and stewards of more than $600 billion” in combined investment capital.^[467]
The letter began: “We are writing to notify you that we will be taking collective action in response to the ongoing and growing economic boycott of traditional energy production industries by U.S. financial institutions.” The signatories wrote their individual actions would be tailored to fit each state’s unique laws and economic position, but that the coordinated objective would be “to select financial institutions that support a free market and are not engaged in harmful fossil fuel industry boycotts for our states’ financial services contracts.”^[468]

Opposition to Federal Reserve Bank appointee (January 2022)

In January 2022, Meier was one of 25 members of the State Financial Officers Foundation (SFOF) who co-signed a letter to President Joe Biden (D), asking him to withdraw the nomination of Sarah Bloom Raskin to the Federal Reserve Bank Board of Governors.^[469]
In a May 2020 New York Times commentary titled “Why Is the Fed Spending So Much Money on a Dying Industry?,” Raskin wrote that Federal Reserve policy decisions should oppose investments in fossil fuels and support investments in the renewable energy sector: “The decisions the Fed makes on our behalf should build toward a stronger economy with more jobs in innovative industries — not prop up and enrich dying ones.”^[470]
Meier and the signatories on the SFOF letter wrote that they were concerned Raskin “would use the supervisory authority as Vice-Chair for Supervision at the Federal Reserve Bank to disrupt the private banking sector, reliable energy supplies, and the U.S. economy.”^[471]
In March 2022, Raskin withdrew her name from consideration for the Federal Reserve position.^[472]

Opposition to SEC proposal to mandate ESG reporting (June 2022)

In June 2022, Meier and 22 other state financial officials submitted a comment to the Securities and Exchange Commission (SEC) opposing an SEC rule proposal titled the “Enhancement and Standardization of Climate-Related Disclosures for Investors.” In December 2022, the Pittsburgh Business Times reported that if the SEC rule were finalized it “would become some of the first mandatory environmental, social and governance (ESG) reporting requirements for U.S. companies, requiring the disclosure of climate-related risk information in registration statements and periodic reports.”^[473]^[474]
“We have watched with dismay as the Commission and other federal commissions and boards have proposed rules and policies that promote political causes that will adversely affect public finance and retirement income,” wrote the state financial officers in the letter. “The Proposed Rule is another such rule.”^[475]

Opposition to Morningstar ratings of Israel investments (August 2022)

In late August 2022, Meier and 17 other members of the State Financial Officers Foundation (SFOF) co-signed a letter addressed to the Morningstar investment rating service expressing their “serious concern regarding reports that Morningstar, Inc. (Morningstar), through its wholly-owned subsidiary, Sustainalytics, negatively rates firms connected to Israel in apparent alignment with the Boycott, Divestment, Sanctions (BDS) movement.” The letter asserted the BDS movement was “antithetical to the global causes of peace, democracy, and human rights” and asked Morningstar to take corrective action immediately to terminate all research and ratings products that treat Israel-connected companies differently than companies operating in other free democracies.”^[476]

Economy and Society: Ballotpedia's weekly ESG newsletter

Economy and Society is a free weekly email newsletter that delivers news and information about the developments in corporate activism; corporate political engagement; and the Environmental, Social, and Corporate Governance (ESG) trends and events that characterize the growing intersection between business and politics. To subscribe, click here. To read all previous editions, please see our archive. Below are the most recent editions:

State financial officer stances on environmental, social, and corporate governance (ESG), 2022-2023

Alabama

Young Boozer (Treasurer)

West Virginia letter supporting financial system access for fuel industry (November 2021)

Arizona

Kimberly Yee (Treasurer)

Letter to John Kerry regarding banking access for energy firms (May 2021)

West Virginia letter supporting financial system access for fuel industry (November 2021)

Divesting state funds from Ben & Jerry’s (September 2021)

Letter to Unilever CEO regarding Ben & Jerry’s anti-Israel policy (December 2021)

Opposition to U.S. Department of Labor ESG rules (December 2021)

Opposition to Federal Reserve Bank appointee (January 2022)

Opposition to Morningstar ratings of Israel investments (August 2022)

Arizona Board of Investment adopts prohibition of ESG criteria (August 2022)

Arkansas

Dennis Milligan (Auditor)

Opposition to Morningstar ratings of Israel investments (August 2022)

Opposition to SEC proposal to mandate ESG reporting (June 2022)

Letter to Department of Labor regarding use of ESG criteria in ERISA decisions (May 2022)

Removal of state funds from BlackRock (March 2022)

Opposition to Federal Reserve Bank appointee (January 2022)

Opposition to U.S. Department of Labor ESG rules (December 2021)

West Virginia letter supporting financial system access for fuel industry (November 2021)

Letter to John Kerry regarding banking access for energy firms (May 2021)

Mark Lowery (Treasurer)

Removal of state funds from BlackRock (March 2022)

California

Malia Cohen (Controller)

ESG Proposals as Candidate for State Controller (2022)

San Francisco Employee Retirement System Fossil Fuel Divestment (2018)

Fiona Ma (Treasurer)

Pro-ESG financial officers’ letter opposing anti-ESG state officers (September 2022)

Support for Stanford University ESG bonds (May 2021)

Membership in Vatican Council for Inclusive Capitalism (December 2020)

Support for ESG nonprofit’s roadmap for California (September 2020)

Opposition to U.S. Labor Department anti-ESG rule proposal (July 2020)

Support for divesting teacher retirement fund from fossil fuel investments (September 2019)

Creation of state-run ESG-focused retirement savings plan (January 2019)

Colorado

Dave Young (Treasurer)

Pro-ESG financial officers’ letter opposing anti-ESG state officers (September 2022)

Connecticut

Sean Scanlon (Comptroller)

Erick Russell (Treasurer)

Pro-ESG statements during state treasurer campaign (2022)

Delaware

Colleen Davis (Treasurer)

Florida

Jimmy Patronis (Chief Financial Officer)

Divestment from Blackrock (December 2022)

Opposition to Morningstar ratings of Israel investments (August 2022)

Opposition to Federal Reserve Bank appointee (January 2022)

Responses to Ben & Jerry’s anti-Israel policy (July 2021)

Opposition to cancel culture in the banking industry (March 2021)

Georgia

Steve McCoy (Treasurer)

Pro-American Energy Letter to President Biden (April 2022)

Letter regarding Municipal Securities Rulemaking Board ESG rules (March 2022)

Idaho

Brandon Woolf (Controller)

Letter regarding use of ESG criteria by S&P Global Ratings ( May 2022)

Illinois

Mike Frerichs (Treasurer)

Pro-ESG financial officers’ letter opposing anti-ESG state officers (September 2022)

Opposition to U.S. Labor Department anti-ESG rule proposal (July 2020)

Russell 3000 Board Diversity Disclosure Initiative (October 2020)

Support for Southern Company net-zero plan (May 2020)

SEC petition seeking mandatory ESG reporting from public firms (October 2018)

Indiana

Daniel Elliott (Treasurer)

Iowa

Roby Smith (Treasurer)

Support for Russian divestment (March 2022)

Kansas

Steven C. Johnson (Treasurer)

Opposition to BlackRock-controlled investments (January 2023)

Election campaign statements (July 2022)

Kentucky

Mike Harmon (Auditor of Public Accounts)

Opposition to U.S. Department of Labor ESG rules (December 2021)