Neuberger Berman Group LLC
NB
Founded in 1939, Neuberger Berman is a private, 100% independent, employee-owned investment manager.
ID: 986461048611-87
Lobbying Activity
Response to Revision of EU rules on sustainable finance disclosure
29 May 2025
Neuberger Berman supports the SFDR's aim to improve transparency on how asset managers integrate sustainability risks. While we support its objectives, the framework faces challenges that must be addressed to deliver decision-useful information and support sustainable finance in the EU: 1. Asset Class Adaptability: SFDR, though described as asset class agnostic, mainly caters to public market strategies and does not accommodate private markets and alternatives (e.g., secondaries, co-investments, CLOs, private credit, commodities, sovereign debt). These asset classes face unique challenges such as data limitations, indirect exposures, or exit constraints. SFDR must be flexible enough for these nuances. 2. Goldplating has led to inconsistent application, undermining the Single Market. Additional national requirements (e.g., exclusions) force managers to tailor disclosures and marketing for each jurisdiction, creating confusion and complexity, hindering passporting, and increasing costs. 3. Complexity of Disclosures: Pre-contractual disclosures (PCDs): We recommend limiting PCDs to 12 pages, focusing on clear, decision-useful content. Machine-readable templates and a centralized database (like ESAP) would improve accessibility. Prospectuses: Overly detailed with ESG content, reducing utility. Entity-Level PAI Disclosures: Can mislead due to data gaps and suggest PAIs are considered across all products, which is rarely the case. Website disclosures: Product-specific website disclosures are lengthy and largely replicate PCDs. 4. Data Availability: SFDR does not address data limitations in companies outside CSRDs scope. The framework should continue to allow estimates, proxies, and tailored KPIs. With CSRD changes, SFDR must align for coherence. Complex or low-coverage data points should allow qualitative context. Proposals for Refining SFDR Support voluntary fund labels, if based on consumer testing and market research. The extent to which unlabelled funds may use ESG language should depend on the breadth of the Commissions final approach to label definitions, with greater flexibility warranted if label categories are narrowly defined. Simplified mandatory templates should retain key disclosures on sustainable investments, DNSH, PAIs, and governance. Segregated mandatesdefined as separate accounts managed for institutional clients outside of pooled fundsshould be exempt, as they are already governed by MiFID sustainability preference rules and professional clients benefit from tailored reporting. We do not support extending product-level disclosures to Article 6 funds. Incidental exposures could mislead if such funds must disclose GHG emissions. Current requirements on consideration of sustainability risks are sufficient. SFDR 2.0 is an opportunity to harmonize with the UKs regime. Regulatory convergence would reduce costs and improve comparability for investors. Categories Sustainable: Support use of the existing sustainable investment definition in Article 2(17). This ensures flexibility, enabling diverse approaches. Agree with PSF proposal to allow either the 2(17) definition or EU Taxonomy alignment; Taxonomy should not be used as the sole tool due to low reporting/changes. Transition: Support PSFs framework for this label, vital for channeling capital into transitional investments. Impact: Support an impact label aligned with the Global Impact Investing Network (GIIN) definition, focusing on pre-defined, measurable, positive social or environmental, governance-related outcomes. Engagement should be recognized as a legitimate impact tool. ESG Collection: The term lacks a clear definition. "ESG" is widely understood as integration of those factors. If the label is intended for such funds, we recommend using "ESG integration". If broader definition (e.g. including engagement/tilts) then "promotion" is more appropriate. Funds solely relying on exclusions should not qualify for a label.
Read full responseResponse to European Sustainability Reporting Standards
7 Jul 2023
Neuberger Berman is grateful for the opportunity to comment on the draft European Sustainability Reporting Standards (ESRS) Delegated Act. As a global investment manager, we commend the European Commission and the European Financial Reporting Advisory Group (EFRAG) for responding to investors calls for crucial sustainability-related information and welcome the efforts to close the current data gaps to achieve the objectives of the EUs Sustainable Finance Action Plan. Please see attached our comment letter on this important consultation.
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