BGA SEC Climate Disclosure Comment - With Attachments
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CFDC ACC II Comments (FINAL)
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California Waiver Restoration Petition
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Pamela King at E&E News writes on the major questions doctrine in a recent article, Inside a legal doctrine that could derail Biden climate regs. She explains, The doctrine—which says Congress must speak clearly if it wishes to allow a federal agency to address matters of “vast economic and political significance”—has been invoked by Republican state attorneys general and conservative…
Boyden Gray & Associates partner Jonathan Berry, formerly head of rulemaking at the United States Department of Labor, filed a letter commenting on the DOL’s proposed Employee Retirement Income Security Act (ERISA) regulation on December 13, 2021. In the letter, Berry decries the rule’s privileging of so-called “Environmental, Social, Governance (ESG)” factors as unlawful and undermining the retirement security of…
Comment on Prudence and Loyalty in Selecting Plan Investments and Exercising Shareholder Rights
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Boyden Gray & Associates filed a comment yesterday on behalf of Consumers’ Research opposing the FCC’s Universal Service Fund (USF). The comment argues that the Universal Service Fund is an unconstitutional tax raised and spent by an unaccountable federal agency. What’s more, this unaccountable federal agency–the FCC– has delegated all authority over this revenue-raising scheme to a private company registered…
Boyden Gray & Associates filed a comment yesterday on behalf of Urban Air Initiative and Consumers’ Research opposing the EPA’s proposed reinstatement of a waiver for California vehicle emission standards. The comment argues that the reinstatement of the waiver would be improper because California’s greenhouse gas emissions standards have been amended since the initial waiver was granted without EPA approval….