Comment Letters

Below are the comment letters received during the public consultation period for the Exposure Draft of the CFA Institute Diversity, Equity, and Inclusion Code (USA and Canada). The list below contains only the comment letters from those individuals or organizations that have given CFA Institute permission to post their letter on its website

The CFA Institute DEI Code is a strictly voluntary code intended to help investment organizations improve diversity, equity, and inclusion in the industry.  It reflects the wider work of CFA Institute to accelerate change, which is why we will be the first signatory.

A public consultation is an important part of our process of creating a new code and the DEI Code is no exception. Thank you to those who sent their responses. They have all been reviewed in detail and some of the suggestions will be included in the final version. 

Overall, we received 100 responses from individuals, firms and other organizations. Stakeholders were comprised as follows: 

Unknown 21%
Consultant/advisor 7%
Investment manager 26%
Investment professional 31%
Asset owner/investor 11%
Other 1%
Service provider 1%
CFA societies 2%

77% of respondents were based in the US, 17% in Canada and 6% outside North America or from an unknown location. Overall 49 members and entities supported the introduction of the DEI Code and 32 opposed. 

The response forms which gave CFA Institute permission to publish can be accessed below. The ones from private individuals have all been anonymized. While some of the views expressed are not consistent with our own and may be considered objectionable, we published them in the interest of transparency. 

We have published almost all of the comments in the interests of transparency, except a select few that contravened civil discourse and decorum.

CAIA Association
California State Teacher’s Retirement System (CalSTRS) / Letter
Cascade Investment Advisors, Inc.
Certified Financial Planner Board of Standards (CFP Board)
Comment 1
Comment 2
Comment 3
Comment 4
Comment 5
Comment 6
Comment 7
Comment 8
Comment 9
Comment 10
Comment 11
Comment 12
Comment 13
Comment 14
Comment 15
Comment 16
Comment 17
Comment 18
Comment 19
Comment 20
Comment 21
Comment 22
Comment 23
Comment 24
Comment 25
Comment 26
Comment 27
Comment 28
Comment 29
Comment 30
Comment 31
Comment 32
IMG Financial
The Independent Trustees of the Morningstar Funds Trust
Institutional Limited Partners Association (ILPA)
Mackenzie Investments
NEI Investments
Portfolio Management Association of Canada (PMAC)
Principles for Responsible Investment (PRI)
Private Family Office
SLC Management
Washington State Investment Board

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