Morrison Foerster is an international law firm with lawyers practicing throughout the United States, Asia, and Europe. Click to discover more.

mofo_share_image.jpg

Morrison Foerster

favicon.ico

favicon-16x16.png

favicon-32x32.png

apple-touch-icon.png

MoFo Favicons

Terms / Notices

Cookies

Privacy Policy

Attorney Advertising

Secure Login

Alumni

  Facebook

MoFo Facebook

  Linkedin

MoFo LinkedIN

Twitter

MoFo Twitter

YouTube

MoFo Youtube

Morrison Foerster - Footer

You have not solved the recaptcha challenge yet or session expired, try again.

Disclaimer

Unsolicited e-mails and information sent to Morrison & Foerster will not be considered confidential, may be disclosed to others pursuant to our <a href="https://www.mofo.com/about/privacy-policy.html">Privacy Policy</a>, may not receive a response, and do not create an attorney-client relationship with Morrison & Foerster. If you are not already a client of Morrison & Foerster, do not include any confidential information in this message. Also, please note that our attorneys do not seek to practice law in any jurisdiction in which they are not properly authorized to do so.

Feedback

mofo-logo-2022.svg

People

Capabilities

Resources

About

Culture

Offices

Careers

Stay Connected

Kelley Howes spoke to Private Equity Law Report about the Securities and Exchange Commission’s (SEC) Division of Examination's ESG-focused risk alert detailing deficiencies and effective practices observed during examinations, among other things.

ESG Risk Alert: Inadequate Controls, Policies and Procedures Concern SEC About ESG Practices Inconsistent with Disclosures

About Morrison Forester

people-default-header-desktop.jpg

people-default-header-mobile.jpg

Default Meta Data

Kelley Howes spoke to Private Equity Law Report about the Securities and Exchange Commission’s (SEC) Division of Examination's ESG-focused risk alert detailing deficiencies and effective practices observed during examinations, among other things.One possible reason why the SEC observed discrepancies between practice and disclosure is that disclosures did not keep up with changes in portfolio management. For instance, managers tend to focus on keeping client-facing documents updated and accurate, but they may forget to do the same for regulatory documents, according to Kelley. “One of the challenges of keeping Form ADV updated is that it is generally updated once a year.”“The compliance team needs to be aware of when the firm’s regulatory and investor documents diverge and when an off-cycle amendment to Form ADV is needed,” Kelley added.Read the <a target="_blank" href="http:https://media2.mofo.com/v3/assets/blt5775cc69c999c255/bltddcd74282c8a923a/627321805f7b601eaaebd352/210615-esg-risk-alert.pdf">full article</a>.

ESG Risk Alert: Inadequate Controls, Policies and Procedures Concern SEC About ESG Practices Inconsistent with Disclosures

Sign Up

Kelley Howes

Co-chair of Investment Management Group

Environmental, Social, and Governance (ESG)