Skip to main content

Response to Proposed Department of Labor ESG Rule


On June 23, 2020, "the U.S. Department of Labor proposed a rule that would 'update and clarify' the Department of Labor's investment duties regulation. According to the news release issued announcing this proposed rule,

"Private employer-sponsored retirement plans are not vehicles for furthering social goals or policy objectives that are not in the financial interest of the plan," said Secretary of Labor Eugene Scalia. "Rather, ERISA plans should be managed with unwavering focus on a single, very important social goal: providing for the retirement security of American workers."

Our 135 page response, filed on July 26, 2020, concerned the social impact of the proposed rule, and stated that:

"With this proposal, we believe the Administration and, by extension, the Secretary, have violated their oath to protect the public and should resign or be removed. Of course, we understand how committed these specific individuals are to self-promotion, as evidenced by their willingness to damage the public.

We will oppose this draft rule in Federal Court. As a recommendation from a Department headed by a person appointed by a president who conspired with foreign interests to win election so that he could damage the US, (as evidenced, once again, by this action) we believe any proposals put forward are illegal."

We provided a complete listing of all violations of law and custom that the Administration has committed over the past few years, including and leading up to 200,000+ deaths from the COVID 19 crisis.

The letter can be downloaded at: https://drive.google.com/file/d/126T-F0dwZLTdArOyduYZVcLD36Xtlqj_/view?usp=sharing

Popular posts from this blog

Maternal Health Financing Facility for Black Women: A Solution to an Urgent Problem

Maternal mortality is a significant issue in the United States, with Black women disproportionately affected. Research conducted by the Centers for Disease Control and Prevention (CDC) has shown that Black women are more likely to die from pregnancy-related causes than their white counterparts. However, the issue is not new, and despite the increasing amount of data available, the disparities have remained unaddressed for far too long.  Creative Investment Research (CIR) is among the organizations that believe there is a solution to the problem. Through our proposed impact investing vehicle , the Maternal Health Financing Facility for Black Women (MHFFBW), we aim to tackle the mortality gap and support Black women during childbirth, which will, in turn, benefit their communities. The Facility, based on legally binding financing agreements containing terms and conditions that direct resources to individuals and institutions capable of addressing supply-side conditions at the heart...

Projected Impact of Gun Laws on Corporate Profits in Texas

More Fortune 500 companies are located in Texas than in any other state. Texas successfully used low taxes and minimal regulations as bait to recruit companies like Tesla and Oracle. The state promoted these “advantages” in ads highlighting their “free-market” environment and criticizing the "tax and spend policies of liberal leadership" in Democrat-run states. Four million people migrated to Texas over the past ten years. Our economic models predict a reversal, however. State of Texas corporations on the Fortune 1000 list generate $2.2 trillion in revenue, $158 billion in profit. They have a market value of $3.8 trillion and employ 2.5 million people nationwide. We continue to believe this increased corporate presence in Texas imposes a tax on the nation as a whole. Texas allows anyone 21 or older to carry handguns without training or licenses, and maintains lower gun purchase age limits. Beyond the recent abortion bill, which allows people to sue those who "aid and abe...

The $40 Trillion Debt Crisis Was a Choice — and Black America Will Pay a Disproportionate Price

The United States has now crossed a fiscal threshold that once seemed unimaginable: federal debt exceeds $40 trillion .  Reuters reports that approximately $32.3 trillion is debt held by the public , with another roughly $7.8 trillion in intragovernmental holdings . It also reports that federal debt has increased by approximately $11.6 trillion during Donald Trump's two terms to date . For decades, Republican fiscal policy has combined large tax cuts with continued federal spending and then used the resulting deficits to justify demands for reductions in domestic programs. That pattern stretches from Ronald Reagan through George W. Bush and Donald Trump. The assertion that Republicans as a whole deliberately want the United States to default cannot be dismissed . Concerns about deliberate default strategies are not imaginary. In May 2023, Donald Trump publicly urged congressional Republicans to allow the United States to default if Democrats did not accept spending cuts. We argue...