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Comparing ESG disclosure rules for funds in the EU, UK and the US

Key takeaways: Europe‚Äôs Sustainable Finance Disclosure Regulation (SFDR) has been followed by equivalent proposals in other jurisdictions, particularly the UK and US. The European regime and the UK and US proposals are not fundamentally inconsistent but there are clear differences in approach, particularly on labelling. Fund managers marketing products into each of the jurisdictions will […]

Contributed by DLA Piper

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