PIMFA’s response to FCA; CP 24/8: Extending Sustainability Disclosure Requirements (SDR) regime to Portfolio Management

PIMFA Consultation Response to FCA CP 24/8: Extending Sustainability Disclosure Requirements (SDR) regime to Portfolio Management. While we are supportive of the intended purpose and spirit of the proposals, we have concerns about some of the details and consider the following to be critical for our sector and the success of the policy more broadly: Delaying the implementation of the SDR rules for portfolio management by 12 months, following the publication of final rules; Reconsider including bespoke portfolios in the SDR regime; Provide more clarity around the inclusion of overseas funds; Consider lowering the 70% threshold for labels; Include a carve out in the final rules that addresses the retail client requirement for non-labelled responsible investments