As revealed by the New York Times and Documented, the State Financial Officers’ Foundation (SFOF) is a corporate-backed group of state treasurers and Republican political operatives that has emerged as a key coordinator of opposition to climate action in the financial industry. This page presents key resources and evidence describing how SFOF has worked to block climate action in the financial industry.

SFOF’s anti-climate advocacy is part of a multifaceted campaign to weaponize state treasurers’ offices against climate change measures. The attacks by SFOF treasurers on climate policy take a variety of forms, including promoting pro-fossil fuel legislation, opposing federal appointments, organizing and filing comments on federal rules, and advancing attacks on specific “woke” asset managers.

SFOF then coordinates the needed sign ons, regulatory submissions, and media rollout for the drafts they provided, often with no public mention of SFOF. SFOF also gives treasurers access to PR professionals and political consultants, to hone messaging and boost the work into the national news media.

SFOF Promotes Legislative Action

• At the November 2021 SFOF Policy Meeting, Derek Kreifels presented on “Anti-Esg investing statutes (TX),” referring to Texas’ SB13, a law passed in June of 2021. The law prevents the Texas government from doing business with companies that “boycott” fossil fuel companies. Similar bills would later pass in other SFOF member states like West Virginia, and have been introduced in dozens more.

• SFOF’s Policy team discussed SB13 on a call in October of 2021, and passed a memo describing the bill to state treasurers.

• In February, 2022, anti-climate policy activist Andy Puzder emailed proposed legislation to West Virginia Treasurer Riley Moore. The proposed bill was “intended to restrict the use of ESG.” Puzder sits on SFOF’s National Advisory Committee.

• In April, 2022, Louisiana Treasurer John Schroder emailed Utah Treasurer Marlo Oaks a draft amendment that would “keep track of companies attacking the fossil fuel industry.” Schroder and Oaks are prominent members of SFOF.

• On May 2, 2022, SFOF members discussed SB 2659, a Tennessee bill that prevents state treasurers from entering into contracts with companies that prohibit “financing to the fossil fuel industry.” The bill passed in Tennessee on May 25th, 2022.

• ALEC Chief Economist and Executive Vice President of Policy and SFOF Senior Policy Advisor Jonathan Williams joined SFOF’s April 18, 2022 call. Williams discussed “two pieces of model legislation that ALEC [had] recently passed,” including “the ACTUAL ALEC model legislation for ESG.”

SFOF Coordinates State Treasurers To Oppose Federal Nominees and File Official Regulatory Comments

Opposing Federal Appointees

• In an email to Idaho Senator Mike Crapo’s office on November 30th, 2021, SFOF’s Kreifels listed four priority issues for the group. The second was “The nomination of Saule Omarova.” Omarova was President Biden’s nominee for U.S Comptroller.

• In December of 2021, SFOF President Derek Kreifels commended “State Leaders” for the role that the letter opposing Saule Omarova had in the nominee withdrawing.

• In January, 2022, SFOF coordinated a letter from treasurers opposing Sarah Bloom Raskin’s nomination to the Federal Reserve Bank. The letter specifically opposed Raskins’ positions on climate change. A memo about Raskin called her an “Anti-energy climate change alarmist.”

• SFOF provided draft tweets and other messaging strategies on opposition to nominee Sarah Bloom Raskin for the Federal Reserve Bank. “We must make as much noise about this as possible… make this THE 'kitchen table' issue in your state this week,” SFOF president Kreifels wrote.

Comments to Rules

• On February 8, 2022, SFOF President Kreifels emailed a draft regulatory comment letter to SFOF member treasurers. The draft responded to the Office of the Comptroller of the Currency’s (OCC) request for comments on a proposed requirement that banks consider climate change related risks. The comment was to be signed, according to Kreifels’ instructions, by “a group of state financial officers and attorney generals.” The letter stated that SFOF would not be publicly linked to the effort. Kreifels wrote: “SFOF Policy Committee will be supporting an effort to provide comment on an open comment period with the office of the U.S. Comptroller of the Currency… this will not be an SFOF letter – but rather a joint effort from a group of state financial officers and attorney generals”

• The final comment, sent to the OCC on February 14th, was signed by over a dozen state’s treasurers and attorneys general, and is indistinguishable from the SFOF draft.

• One of SFOF’s central complaints about the OCC’s draft rule centered on denying the relative importance of climate change. The comment critiqued the proposed rule because it “single[d] out climate-related risk alone for special treatment, despite more serious threats that include economic downturns, foreign wars, and public health crises.Climate-related financial risk is not the gravest threat to our banking system and should not be elevated to that status over economic downturns” read the final submission.

• SFOF treasurers sent a similar letter to the Federal Deposit Insurance Corporation (FDIC) on June 3, 2022 regarding the agency's draft "Principles for Climate-Related Financial Risk Management."

• On December 9, 2021, Derek Kreifels sent a draft regulatory comment letter to SFOF member treasurers and requested that they sign on to the letter. The comment, drafted by Utah Treasurer Marlo Oaks, responded to the Department of Labor’s proposed rule allowing retirement plans to consider climate change risks in their investment strategy.

• The final comment, submitted December 13th to the DOL’s Employee Benefits Security Administration (EBSA), was signed by over a dozen state treasurers.

• On March 1, 2022, Kreifels sent an outline of a comment opposing a climate related disclosure rule under consideration by the Municipal Securities Rulemaking Board (MSRB) to SFOF member treasurers. Because the MSRB is not a government agency, there is no public record of the final letter.

SFOF Produces and Promotes Advocacy Letters

• In May, 2021, SFOF coordinated additional sign ons for a letter to Presidential Envoy John Kerry, which criticized Kerry’s alleged attempts to restrain financing to fossil fuel projects. In an email, West Virginia Treasurer Riley Moore asked SFOF for help getting signatures for the letter. With SFOF’s support, the letter's signatories went from four to fifteen.

• In November, 2021, West Virginia Treasurer Riley Moore sent a letter addressed to the “U.S Banking Industry,” notifying them that the signatories would be “taking collective action in response to the ongoing and growing economic boycott of traditional energy production.” The letter was signed by 16 SFOF treasurers. While SFOF was not publicly involved, the letter follows a pattern set by other advocacy letters coordinated by SFOF.

• On April 21, 2022, the Utah Treasurer Marlo Oaks sent a letter to S&P Global Ratings president Martina Cheung. The letter, signed by Utah’s Federal and State delegations, objected to S&P’s plan to publish climate related disclosures as part of credit ratings for states.

• On April 22, 2022, in an email praising Oaks for the letter, SFOF claimed credit for being “key in helping with the national news coverage” of the letter.

• On April 25, 2022, Treasurer Oaks addressed an “S&P Global letter” on an SFOF call.

• The same day, West Virginia Treasurer Riley Moore sent his own letter denouncing S&P.

• On June 17, 2022, 23 state financial officers sent a letter to the SEC detailing their opposition to the Securities and Exchange Commission’s proposed climate disclosure rule.

SFOF Drives Attacks on Asset Managers for Their Climate Policies

• On November 3, 2021, BlackRock was the first topic of conversation at an SFOF policy meeting focused on “The continuing “ESG” and “Wokeism” Attack on Economic Freedom.” Since then, SFOF meetings have focused on opposition to financial industry attempts to address climate change. SFOF specifically focuses on ESG disclosure.

• The November 3, 2021 Policy Meeting included a session on "The Continuing 'ESG' and 'Wokeism' Attack on Economic Freedom."

• SFOF’s February, 2022 National Meeting featured a “Private ESG Academy'' hosted by SFOF’s subject matter experts.

• “ESG discussion: How Do We Protect the Role of the Fiduciary” was also a topic at SFOF’s February 2022 National Meeting.

• In December of 2021, SFOF provided a specific set of questions about climate related measures “for use during investment council/pension board meetings.” Questions included “Please explain the extent and nature of your involvement, if any, in the climate action 100+”

• In an April 22, 2022 email from Louisiana Treasurer John Schroder to West Virginia Treasurer Riley Moore, Schroder bragged that he “moved over 600 million out of Blackrock accounts.” Schroder also referenced “specific questions” banks must answer to become eligible for Louisiana state government business.

• SFOF’s social media regularly attacks BlackRock by name. For instance, SFOF commended Kentucky Treasurer Allison Ball for “standing up to woke companies like @BlackRock who are hypocritically pushing for carbon neutrality in the U.S., but are kowtowing to the CCP in order to do biz there.”

SFOF Provides Public Relations Management for Treasurers

• SFOF backstops treasurers’ political work by providing access to professional public relations and political consultants. SFOF called these “tools to support you and your offices” in an email from Kreifels to SFOF members on November 9, 2021. The email offered a weekly “issues/misc” call with JAG Public Affairs’ Jonathan Grella.

• SFOF PR seems to be influential in driving media coverage on key issues. In April, 2022, Kreifels wrote to congratulate SFOF members on the letter opposing the use of climate risk in S&P ratings. “Our new public relations firm has been key in helping with the national news coverage” he wrote.

• SFOF featured a Fox News video on its Youtube channel promoting Moore’s energy boycott initiatives in West Virginia, titled ‘Investing in BlackRock hurts West Virginians,’ treasurer says, 'a clear conflict of interest.' The group also promoted Moore’s interview with Laura Ingraham following the announcement that the state would divest from BlackRock.

• SFOF also provides a link from state treasurers to national level political operatives, like CRC Advisors. CRC Advisors, which is run by activist Leonard Leo, provides media and strategic support to a wide web of far-right political groups. In April, 2022, SFOF president Derek Kreifels connected West Virginia Treasurer Riley Moore to CRC Advisors regarding media requests.

• SFOF is sponsored by The Singularis Group, a political consultancy tied to Republican Senator Josh Hawley (R-MO) and similar far-right extremists. The Singularis Group was a “platinum” sponsor for SFOF’s July 2021 meeting in Salt Lake City.

For more information contact:

Jesse Coleman, Senior Researcher at Documented ([email protected])

Colette Rosenberg, Researcher at Documented ([email protected])

Or see our additional investigation on SFOF.