SBAI Response to SFC on Climate Related Risks

SBAI responds to SFC’s Consultation Paper on Climate Related Disclosures focusing on sequencing, ESG beyond climate, flexible risk management regulation, and thresholds for enhanced reporting.

In response to a consultation on asset manager disclosure we raised the following points:

• Disclosure should be mandated at the issuer level before the fund manager level.
• Climate risk is being elevated as a risk factor and treated differently from the typically principles based approach to risk management regulation.
• Any risk management regulations should retain flexibility given the diverse nature of the alternative investment industry.

Enhanced standards should apply to fund managers running dedicated ESG products rather than managers over a certain AUM threshold.

SFC HK Consultation Paper on Management and Dislcosure of Climated-Related Risks by Fund Managers (October 2020)