The SEC has proposed new rules requiring ESG disclosures by registered funds, BDCs and registered investment advisers. The SEC’s stated goal in proposing the new ESG disclosure requirements is to promote consistent, comparable, and reliable information for investors concerning funds’ and advisers’ incorporation of ESG factors. The SEC is concerned that this lack of consistent, comparable, and reliable information can create a risk of a mismatch between advisers’ and funds’ actual ESG considerations and investor expectations, and that funds and advisers may be marketing such strategies in a way that exaggerate their ESG practices (known as “greenwashing”). While the proposal itself was expected – and the goal of the proposal widely supported – the breadth of impact is surprising. Nearly all investment managers and funds will be impacted to some degree by the new rules if adopted in their current form.  Presented by George Raine, Partner at Ropes & Gray LLP and Tess Virmani of the LSTA.