Frequently Asked Questions | Illinois Sustainable Investing Act

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Frequently Asked Questions

Find answers to the most common questions about the Illinois Sustainable Investing Act. If you can’t find what you’re looking for here, please contact us.

Why does sustainable investing matter?

Sustainable investing gives investors a more complete view of an investment’s overall risk profile and return potential. It adds useful information that may not appear in traditional financial analysis alone.

Who does the Illinois Sustainable Investing Act apply to?

All public entities in Illinois that have public funds within their custody are subject to this law. This law applies to all current operating funds, special funds, interest and sinking funds, and any other funds. What that means for you is that changes will need to be made to the investment policy statement to reflect that sustainability factors are being incorporated into investment decision-making related to funds in your custody. The investment policy should include material, relevant, and decision-useful sustainability factors to be considered in evaluating investment decisions. Sample policy language can be found on our website. 

The implementation of this integration can vary based on how funds are managed. For instance, if an investment manager is used, you can ask questions during the manager selection process or after selection to better understand how the manager is accounting for these investment risks. We have sample Sustainability Due Diligence Questionnaires for Investment Manager Evaluation and Security Analysis Due Diligence available on our website for your reference. 

Please note that the Treasurer’s Office cannot provide legal advice on whether specific language brings an entity into compliance with any statute. If you have specific legal questions, you should contact your attorney. 

Do public entities in Illinois need to update their investment policies?

Yes. Public agencies in Illinois that have public funds in their custody must update their investment policies to reflect that sustainability factors are incorporated into and considered in investment decision-making for those funds.

What happens if an investment policy is not updated, and are there any additional filing requirements?

Not updating the policy may expose the entity to audit or litigation risk. In addition, entities subject to the Illinois Pension Code must file a copy of the updated investment policy with the Department of Insurance within 30 days after adoption.

The Illinois Municipal League (IML) published a fact sheet that says the Act “strongly encourages public agencies and governmental units to develop a sustainable investment policy but does not mandate them to do so.” Do others share this view?

All public agencies in Illinois that have public funds in their custody must update their investment policies to reflect that sustainability factors are incorporated into and considered in investment decision-making for those funds. Not doing so might expose the company to audit or litigation risk.

Is there a sample Investment policy that includes these changes?

Yes, a sample can be found on the Illinois State Treasurer’s website. Please note that the Treasurer’s Office cannot provide legal advice on whether specific language brings an entity into compliance with any statute. If you have specific legal questions, you should contact your attorney. 

How does the Treasurer evaluate investment managers regarding sustainability factors?

During our due diligence process, in addition to questions about traditional financial factors and metrics, we also ask prospective managers a range of questions about incorporating sustainability factors. We have a sample Sustainability Due Diligence Questionnaire available on our website for your reference. 

Why is this important for public funds?

Public funds have a fiduciary duty to make careful investment decisions. Considering sustainability factors can help them better meet that duty by using more complete information when evaluating investments.

How can I learn more about The Illinois Funds as an investment option?

Visit the Treasurer’s Office, The Illinois Funds information, and policy resources to understand objectives, eligible instruments, and how the program is managed.