Our view and that of others who share our aims (such as UKSIF and ShareAction) is that this is a hugely important paper and well worth responding.
As such I am interested in speaking with financial services professionals who would like to discuss this consultation either to help inform my response – or to help shape their own.
If you would like to get in contact please contact me on julia@sriServices.co.uk as I would ideally like to bring interested parties together to discuss this in the near future.
Meanwhile here are a few thoughts about what the ‘look and feel’ of my response will be:
Welcome. It is truly great that the FCA is consulting on this area. We can not address climate change without the support of the financial markets. We do however recognise this is their first step into this area and our feedback is the spirit of encouragement…
Tone. The tone of this paper feels rather low key. The FCA could become hugely useful in the fight against climate change and I am not sure they recognise this.
Scope. The scope of this paper feels rather narrow. Green Finance is essential, but so is changing the way existing business operate. (They are not about to disappear!) Supporting today’s excellent companies, avoiding laggards and engaging for change are all important practices.
Timing. The paper appears not to recognise the urgency of this topic. Assuming the IPCC are right we have 12 years to start to properly address climate change. This puts climate risk (and investment opportunities) firmly within the scope of today’s investors. (We can no longer afford to procrastinate).
Knowledge. I understand that the FCA feels under pressure in this area and that this is a poor fit with much of their activity. There are however many people in the financial sector who have worked in this area for a long while who will help them (eg experienced SRI fund managers and others). There are also initiatives such as TCFD that have already done much of the ‘heavy lifting’. These can add to their knowledge base and accelerate progress.