“ESG Check in”: More details on the Securities & Exchange Commission’s Activist Role in the “Whole of Government” Push on ESG, “Climate Risk Disclosure”


The indispensable transparency-in-government group Energy Policy Advocates has provided GAO a review of record productions from FOIA litigation with the Securities & Exchange Commission, including specifically from calendars of Chairman Gary Gensler and then-Commissioner Allison Herren Lee.

Between the near-obsession with advancing the “ESG” and “Climate Risk Disclosure” agenda which these reveal, and emerging information about an apparent revolving door example that’s ostentatious even by Washington standards, GAO feels bold to say that an inquiry into the Securities & Exchange Commission’s seemingly disproportionate focus on CRD and ESG, and its execution of this agenda, is warranted.

Factors includes:

  • Calendars for Chairman Gary Gensler and then-Commissioner Allison Herren Lee show a disproportionate investment of time and attention to CRD and ESG, troubling on its face but of course also arguably evincing Commission leadership’s distraction from emerging, major financial market problems (e.g., FTX/Alameda)
  • These are not the publicly available calendars, but calendars that Energy Policy Advocates had to sue to obtain. These often contain details scrubbed from the public versions
  • SEC heavily redacted these calendars, which is the subject of continuing litigation. Also, thanks to the same group, soon the SEC will have to produce the Biden transition-team plan, related records and all Biden campaign communications over a relevant period of time (re possible evidence of politicization)
  • Notably, the principal financier of the CRD/ESG advocacy campaign is a foreign “ESG investor”, Sir Christopher Hohn. As a GAO paper this past summer showed, Hohn has very close ties to Chinese officials but, more concerning still, also is concurrently financing the complementary “climate litigation” campaign, with tens of millions of dollars (despite denials of involvement in the U.S. climate litigation, records trace funds run through an opaque group in the Netherlands)
  • The SEC’s position is that it must impose ESG, e.g., the CRD rule, because investors demand it. This is true so far as it goes (see Hohn, Christopher, BlackRock, et al.), if not as the SEC implies. For more detail, see GAO’s comments here. Yet, given information developed over years of open records pursuits which leaves no doubt about CRD’s political and activist origins (led by New York AG’s Office, Ceres, BlackRock, and the obligatory Rockefeller interest), and pre-rule, high-level (Genslercoordination with the Biden White House Climate Office, this claim seems pretextual
  • Calendars indicate that that coordination with the White House began in May and June 2021 at the Gensler level, carried on by his staff in September and December 2021
  • And now we have an apparent revolving door example that is ostentatious even by Washington standards

Regarding the latter, raising possible conflicts and undue influence issues re the climate risk disclosure rule, “Kristina Wyatt left the SEC [in February 2022] to join Persefoni, a climate management and accounting platform, as its deputy general counsel and senior vice president for global regulatory climate disclosure. Wyatt was serving as senior counsel for climate and ESG to the director of the Division of Corporation Finance at the SEC — she is steeped in the processes and decision-making that has underpinned this proposed ruling.”

The CRD rule public comment docket shows that Persefoni, a little-known but well-funded startup, held a disproportionate number of meetings with SEC staff compared to other advocates. It seems most likely that Persefoni was pushing its methodology for claiming the climate rule’s cost, given that the SEC has been unable to provide any methodology or citation for its lowballed cost of compliance estimate for CRD, and the only figure that comes close to the SEC’s comes from a survey jointly commissioned by Ceres, ERM and Persefoni.

The sheer volume of senior staff time dedicated to this issue, including canoodling with activists, is troubling. That this is all in pursuit of a political agenda item demanded by investors, yes — ideologically activist investors, including obvious rent-seekers — is another story entirely.

Each of these AHL items is distinct, btw

Energy Policy Advocates’ FOIA litigation with SEC continues on several fronts — one matter has revealed a four-alarm fire at the Biden White House when SEC passed along a FOIA request for correspondence between the two, “Importance: High”, to which the White House replied, “Has this production been flagged for OMB, CEQ and the WH Military Office?”. Expect more calendars, other documents and, ultimately, removal of certain redactions in coming weeks and months. GAO will stay on top of these important developments and this critical issue.

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January 16, 2023 10:45 am

The WEF and ESG have their tentacles in every government from cities to the top. Despite most sane people realizing both are obvious Socialist/Communist cabals intent on controlling the daily lives of all the people in the world they still have momentum. Are people too lazy to push back or do they really believe the narrative because it’s being supported by the MSM?

Scarecrow Repair
Reply to  mleskovarsocalrrcom
January 16, 2023 11:44 am

I don’t think socialism or communism or even fascism really enters into it, even though fascism may be a bit closer. But all they really want is control, and ideology has nothing to do with it.

The Karens who complain about unmasked people only 5 feet apart — that is a much better analogy. Control, not ideology.

Reply to  Scarecrow Repair
January 16, 2023 1:50 pm

Except all the Karens that complained about unmasked people were leftists.

Spoke with a man today that leans far left, he ALWAYS listens to NPR, about every AP report about weather mentioning that “climate change” is making storms worse and more often. (2 articles in the Las Vegas Review Journal today from the AP). And that that was not the case, and even the IPCC says it is not.

I could see his eyes roll up into his head.

Reply to  Drake
January 16, 2023 5:44 pm

I have a lefty friend like that who refuses to accept any objective views regarding Brexit, Trump, Covid, Ukraine or climate change.

He’s entirely bought into them 100%, despite the UK government being ‘right wing’ (that’s a laugh as well) for the last 12 years.

Reply to  mleskovarsocalrrcom
January 16, 2023 12:55 pm

Except for the 5000 soldiers with automatic weapons and full high capacity magazines, who won’t allow it, the roads from the airport, where hundreds of private jets with unvaccinated pilots fly in attendees, would be lined with adoring unaborted children holding flowers.

Reply to  mleskovarsocalrrcom
January 16, 2023 4:11 pm

Of all TLAs (Three Letter Acronyms) the most sinister has to be WEF, and their dark triad of neo-Marxist/Gnostic policies: ESG (Environment, Sustainability, Governance), SDG (Sustainable Development Goals) and SEL (Social and Emotional Learning). These people see themselves as the rightful rulers of the entire world (by their own reckoning), they have no compunctions in regards to how many people they crush in their pursuit.

Izaak Walton
Reply to  MarkH
January 16, 2023 4:56 pm

“neo-Maxist/Gnostic policies”? What exactly is a gnostic policy? Does it involving believing that the gnostic gospels are the literal word of god or is it something completely different?

January 16, 2023 10:54 am

If it was true that investors were demanding ESG, then it would be simple enough for them to vote for ESG at the next shareholder meeting.

The truth is that only a small percentage of investors are demanding ESG.

Reply to  MarkW
January 16, 2023 1:52 pm

BUT, they are set up to meet the standards, and thus use government against those who do not, so as to improve their bottom line.

HOW are they set up, you may ask, by being the ones who write the rules.

January 16, 2023 11:20 am

Government by and for advocacy groups, not you.

January 16, 2023 11:22 am

Bad ideas always have to be crowbarred in.

It’s for your own good

Reply to  strativarius
January 16, 2023 4:14 pm

It’s not even for your own good, it’s “for the greater good”, which means that they can actively harm people and justify it. When they line you up along a ditch in a paddock, they will justify it as being “for the greater good”.

January 16, 2023 11:47 am

“The SEC’s position is that it must impose ESG, e.g., the CRD rule, because investors demand it. This is true so far as it goes (see Hohn, Christopher, BlackRock, et al.), if not as the SEC implies. For more detail, see GAO’s comments here. Yet, given information developed over years of open records pursuits which leaves no doubt about CRD’s political and activist origins (led by New York AG’s Office, Ceres, BlackRock, and the obligatory Rockefeller interest), and pre-rule, high-level (Genslercoordination with the Biden White House Climate Office, this claim seems pretextual”

This is crap. Those same investors (see Hohn, Christopher, BlackRock, et al.) do not demand it elsewhere & the SEC knows that. Investors that demand that all (non-China) regulators impose ESG evaluations/criteria are playing a game and demanding that the SEC play along.

Last edited 20 days ago by DonM
John Oliver
January 16, 2023 11:53 am

More proof that however bad and corrupt you think this administration is- its worse. Some times they don’t even bother to hide it. For example , Biden to migrants “wait till I’m elected, then surge the border” . Frustrating, galling.

Rud Istvan
January 16, 2023 1:07 pm

Elections have consequences. Stolen elections have severe consequences.

  1. Much of the current administration is inept, incompetent, or worse. This includes Biden, Harris, Buttigieg, Granholm, climate ambassador Kerry, and many more.
  2. Some of the agendas are disastrous. Open borders, inflation, climate (cancel KXL day 1),…
  3. Some of the agendas are merely foolish, as the undue SEC focus on ESG and CRD instead of the massive FTX crypto fraud. Going after Gemini for unregistered crypto securities is closing the barn door after the horses escaped.
January 16, 2023 1:54 pm

There is no climate crisis.

Unsettled: Climate and Science | Dr. Steven Koonin | EP 323

Jordan B Peterson Podcast

Tim Spence
January 16, 2023 2:00 pm

There’s never been a shortage of conmen in the world but never have they been so organized.

Keith Ball
January 16, 2023 2:35 pm

What government body passed the ESG or CRD? What makes any part of these legal?

Rud Istvan
Reply to  Keith Ball
January 16, 2023 3:07 pm

In fact, ESG goes expressly against long established corporate law including the statute that established the SEC. The only duty fiduciaries have is to maximize shareholder financial returns. NOT environment and social.
And there is no ‘near term’ climate risk to disclose no matter what non-expert SEC admin might think. Even the IPCC doesn’t see such ‘near’ climate risk, after they looked (weather extremes). Speculating about a far off future is expressly frowned upon by the SEC in things like offering perspectuses, because it becomes blue sky. 3-5 year financial projections are normal, 10 years is really pushing the envelope.

January 16, 2023 5:37 pm

A few questions.

Being that Joe Biden seems in a bit of hot water at the moment, were he to be ousted from his job as POTUS would that make any material differences to ESG projects?

If Ukrainians fail to kick Russia out of the country will that make any material difference to this as there would likely be a substantial geopolitical relationship change across the world and quite probably significant geo-economic changes. I have read comments to the effect that UN voting habits indicate much of the global south including China and India are aligning themselves more closely with Russia than America and a victory in Ukraine could see more prominent countries like Saudi Arabia cementing already growing relationships with Russia.

As I see it, if Russia prevails the credibility of NATO will be called into question by many member nations. Albeit Ukraine isn’t a member it’s an open secret that it’s armed forces have been provisioned and trained by NATO since at least 2014, yet NATO will be seen to have failed it by the rest of the world.

The west will be faced with a country with enormous natural resources partnering with China, with huge industrial resources when the US and the UK have lost much of their manufacturing base over the years and oil and gas is being curtailed by the Biden administration in the US.

Whilst its tempting to compare GDP with Russia we need to consider that the US and the UK are both saddled with eye watering debt, huge welfare systems and enormous healthcare provision. Furthermore, our education systems are producing around 3% of engineering graduates whilst I believe Russia is around 23% and China possibly more.

Our demographic time bomb is also hitting the west. We boomers have reached, or are reaching retirement age which will have significant financial implications for our countries as investment habits change to consolidation rather than speculation. Workforces will be dramatically reduced almost overnight which will see fewer people chasing more jobs thereby hiking up labour rates and further widening the gap between us and the 2nd/3rd worlds.

It seems there is also a social implication. Whilst countries like Iran, China, India and Russia all have cultural and religious differences, I have also read that as Russia has moved towards restoring its orthodox Christian church since the wall came down, those other countries have a grudging respect for traditional values rather than the hedonistic lifestyles we have adopted in the west.

John Oliver
Reply to  HotScot
January 16, 2023 5:57 pm

During most of my adult life no matter how bad things seemed – Vietnam, watergate, possible nuclear war, 9/11, financial crash; I always still felt 95% sure the US would recover the world would stabilize. I’m down to 50% now.

Reply to  John Oliver
January 17, 2023 3:36 am

I suspect that if Ukraine fails to kick Russia out there will be change in the world which might not be entirely bad. The west will be forced to face it’s own hegemonic desires and begin diplomacy rather than violent imperialism.

The chant is Russia, Russia, Russia and China, China, China but certainly all China has done so far is to take advantage of the west’s greed (internal politics excepted) and stupidity. We willingly allowed China to become the world’s manufacturer, then complain they make everything in the world.

Why should either country be forced to accept our LGBTQ, BLM and antifa politics? Why should we be even commenting on their treatment of, for example, Uighur Muslim’s, when a large proportion of the west lives in fear of Muslim immigrant violence and cultural influence? Indeed, wasn’t it the west that mounted the War on Terror, specifically against Islam, during which we killed millions?

The USSR did precisely what the west wanted; conversion from communism to capitalism, and the break up of it’s own empire. Yet we have continued to demonise Russia. Our oligarchs are apparently moral and incorruptible whilst their’s are immoral and corruptible.

And whilst China operates an oppressive communist government, it’s now propped up by naked Capitalism. If Capitalism is so righteous shouldn’t it logically eventually displace communism altogether?

We condemn both countries for their surveillance state and propaganda culture whilst, I believe London, England has more CCTV camera’s than any city in the world. Our supermarkets operate facial recognition (for the sake of security, allegedly) and we know our mainstream media is entirely bought and paid for by our governments. Even the BBC is state controlled, under the guise of a public service broadcaster.

Whilst the US and Europe has been shown to be operating clandestine state interference in free speech platforms like Twitter and Facebook with arrests for ‘inappropriate’ post’s, China controls access to social media for Children (e.g. no access after 6pm for those under 14 and instead of uncontrolled advertising short educational clips are played).

I’m not making a case for either countries, just drawing some comparisons.

Mark Whitney
January 17, 2023 6:34 am

A good scam requires much planning.

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