On July 30, 2020, the American Retirement Association wrote to the Department of Labor to provide our views on their proposed rule concerning Financial Factors in Selecting Plan Investments. Specifically, ARA does not believe DOL guidance should discourage ERISA fiduciaries from considering environmental, social, governance (ESG) factors as they evaluate plan investment options nor should these types of investments be prohibited from being used as a Qualified Default Investment Alternative (QDIA).