October 5th 2020
Response to the DWP’s consultation on taking action on climate risk
LAPFF responded to the DWP’s consultation on taking action on climate risk. Although this consultation does not cover reforms which will affect LGPS funds, as pension regulation and legislation for the LAPFF’s sector tends in the end to mirror those within the purview of DWP the Forum wished to submit a response. The Forum stated its support for the introduction of mandatory carbon emissions and risk reporting and set out areas which it felt the proposals could be strengthened.
October 5th 2020
Due Diligence on Forest Risk Commodities Consultation
LAPFF responded to a Government consultation on whether it should introduce a new law designed to prevent forests and other natural areas from being converted illegally into agricultural land. The forum encouraged the Government to do so, but highlighted that there could be issues with it applying just to ‘large’ businesses and further encouraged the scope of the legislation to apply further than it appeared to.
September 25th 2020
IIGCC Draft Framework Consultation
LAPFF responded to the IIGCC Paris Aligned Investment Initiative: Net Zero Investment Framework for Consultation. The Forum congratulated the IIGGC on producing the framework document, and made a few general comments aimed strengthening the document.
September 24th 2020
FCA: Proposals to enhance climate-related disclosures by listed issuers and clarification of existing disclosure obligations
LAPFF has submitted a response to the FCA’s consultation on proposals to enhance climate-related disclosures by listed issuers and clarify existing disclosure obligations. The Forum welcomed the proposals but called for a mandatory approach.
September 18th 2020
PRI Human Rights Framework Consultation – LAPFF Response
LAPFF welcomes this framework in highlighting the importance of human rights as a financially material consideration for investors.
September 2nd 2020
LAPFF has written to the BEIS Select Committee, the Secretary of State and the Law Commission regarding the problems with the International Accounting Standards Board consultation on revisions to international standard IAS 1
The LAPFF letter to the FRC of 1 September 2020 has been followed up by three further letters.
LAPFF also makes the point that so-called ‘ investors’ who purport to support the international accounting standards tend to be a less than qualified group that has been cultivated by the standard setting parties, and don’t actually represent investors. LAPFF tends to support the views of more credible real investors such as Warren Buffett and Charlie Munger of Berkshire Hathaway who are openly derisory of the approach the international standards take.
September 1st 2020
LAPFF has written to the Financial Reporting Council on its response to the International Accounting Standards Board consultation on revisions to international standard IAS 1.
The LAPFF letter points out that the purpose of accounts described by IAS1 and agreed by the FRC (to be ‘useful to users’) doesn’t agree to the statutory purpose (which is for capital maintenance), and the wording in IAS1 does not agree to the legislation. The new procedures following Brexit require new standards to be agreed by the Secretary of State and then Parliament.
July 31st 2020
Response to DfT consultation on ending the sale of new petrol, diesel and hybrid cars and vans
The Department for Transport issued a consultation on ending the sale of new petrol, diesel and hybrid cars and vans by 2035. The Forum strongly supports bringing forward the end to the sale of new petrol and diesel cars and vans but calls for an earlier date of 2025 to be set. The Forum also welcomes the inclusion of hybrids in the phase out but considers that a clear strategy and policies are required for all road vehicles, including heavy goods vehicles.
July 16th 2020
LAPFF Response to the GRI Tax Standard Consultation
LAPFF welcomes this standard and its content as a positive way forward on tax transparency and payments to governments. The Forum’s response focuses on ensuring appropriate accountability structures for corporate tax practices and an alignment with existing ESG standards.
June 23rd 2020
International Accounting Standards IAS 1
LAPFF considers IAS 1 to have serious flaws. Parliament in 1945 and 1962 concluded that ill-informed parties in investment wanted ‘exit values’ rather than costs in accounts, and had to point out that exit values are only relevant when a business is not a going concern and about to be broken up. Unfortunately the International Accounting Standards Board (IASB) by force of presence, rather than force of logic, adopted the model that Parliament ruled out. The IASB has sought to have assets and liabilities at value, similar to the break up basis. The irony, is that makes it more likely that a business will need to be broken up, as the ingredients to show whether a business is funded from profits and properly capitalised are missing.
February 3rd 2020
SEC Request for Comment – Proposed Rule Changes for Filing Shareholder Resolutions
The SEC issued a consultation on proposed changes to the filing thresholds and rules for submitting shareholder resolutions in the US. Overall, LAPFF did not support the proposals as they would make the filing process even more onerous than it already is, and they would discriminate against small shareholders.
January 28th 2020
NZ Climate Reporting Consultation Response
LAPFF has responded to the New Zealand Government consultation on their proposal to mandate companies to report in a consistent and defined manner how climate change impacts their business and investments. LAPFF agrees with the proposals for new mandatory reporting requirements which should be widespread and implemented on a comply or explain basis. LAPFF agrees that the TCFD Framework is currently best practice for climate related decisions and that the adoption of climate related reporting will improve decision making within the companies and make it easier for investors to accurately quantify long term value of the companies in which they invest.
September 17th 2019
Transparency in Supply Chains Consultation
The Government issued a consultation on how to make the supply chain transparency component of the Modern Slavery Act more effective. LAPFF has reviewed the Independent Review and its recommendations for necessary changes to the Modern Slavery Act. Overall, LAPFF is supportive of the Independent Review’s suggestions.
June 3rd 2019
Response to the Independent Review of the Financial Reporting Council
LAPFF has responded to the review on the proposed replacement of the Financial Reporting Council (FRC). LAPFF has had concerns about accounting and audit practices since the banking crisis and has stated for some time that there was leadership failure with the FRC, that the FRC needed to be disbanded and replaced, that the position of standard setting and enforcement should be separated, and that the new body should be constituted by statute and accountable to Parliament. This response aims to outline LAPFF’s position on the recommendations outlined in the Kingman Review.
February 5th 2019
Climate Change and Green Finance Submission by Sarasin & Partners LLP and Local Authority Pension Fund Forum
Along with Sarasin and Partners LLP with whom LAPFF submitted this response, the Forum would welcome the FCA, alongside the reconstituted Financial Reporting Council (FRC) 2, confirming the existing requirements for transparent reporting of climate-related risks and providing supportive guidance for how companies should meet their obligations to ensure full disclosure and to support comparability.
August 16th 2018
LAPFF Response to the Kingman Review of the Financial Reporting Council (FRC)
LAPFF ‘s response focuses on incompatible functions of the current FRC structure that need to be recognised when coming up with solutions. The response also suggests that the Parliament must be involved in the outcomes to uphold the public interest.
March 8th 2018
Consulting on a Revised UK Corporate Governance Code
LAPFF’s response focuses on the FRC’s own governance problems and raises the incongruity of the FRC campaigning on the importance of ‘culture’. The response also calls for more legal requirements to ensure that stakeholder voices of all types are taken into consideration, in particular those of employees and consumers, and notes the lack of action on executive pay.
January 31st 2018
Financial Reporting Council consultation – Draft amendments to Guidance on the Strategic report Non-financial reporting
LAPFF has responded to the FRC consultation on draft amendments to Guidance on the Strategic Report Non-financial reporting. The response emphasised that as an investor forum, LAPFF believes that robust rules, application and practice on accounting and financial reporting are essential to safeguard the interests of pension fund beneficiaries.
October 13th 2017
LAPFF Response to UK Listing Authority Consultation CP17/21 ‘ Proposal to create a new premium listing category for sovereign controlled companies
LAPFF welcomes the opportunity to respond to the Consultation. As an investor forum, LAPFF believes that addressing the rules pertinent to the listing regime is essential to safeguard the interests of pension fund beneficiaries.
May 8th 2017
The UK’s listing regime – response to FCA consultation
LAPFF’s response focuses on how to ensure that the UK Listing Regime is fit for purpose and focussed on shareholder and creditor protection, not other market agents’ interests. LAPFF’s response sets out that LAPFF believes that the UK Listing Authority (UKLA), being a unit within the Financial Conduct Authority (FCA), is in the wrong place. LAPFF sets out that there also needs to be clarity as to the investor protection provided by Listing Rules and the investor protection provided by company law.
The current regulatory framework has significant problems, not least due to the Financial Reporting Council (FRC) not dealing with existing company law protections properly.