US SEC will not charge top funds over climate concerns but warns of disclosure obligations
BLK•The SEC said it will not charge top asset managers over their work with Climate Action 100+ ahead of ExxonMobil’s 2021 shareholder meeting. The agency warned that some climate-related activism could affect eligibility for cheaper disclosure forms and urged large investors to review their obligations before next year’s proxy season.
1. No charges announced
The SEC said it will not charge asset managers over their actions with Climate Action 100+ ahead of ExxonMobil’s 2021 shareholder meeting. BlackRock, Vanguard and State Street were among the firms mentioned by the agency; none immediately commented on the report.
2. Disclosure obligations
A rare SEC report said membership in an organization seeking to influence control of a specific issuer could be a factor in losing eligibility to use cheaper disclosure forms. SEC officials said traditional investor communications remain possible, and the agency urged large investors to review their regulatory obligations ahead of next year’s proxy season.
3. Climate engagement context
Climate Action 100+ aligned with activist hedge fund Engine No. 1 before Exxon’s 2021 meeting, where BlackRock, Vanguard and State Street backed some dissident directors. BlackRock and State Street left Climate Action 100+ in early 2024; Vanguard never joined.




