As companies and investment managers increasingly offer products, including investment funds, whose strategies incorporate environmental, social and governance (ESG) factors, the SEC has repeatedly emphasized its intent to combat "greenwashing"—i.e., false or misleading claims by companies and advisers relating to their ESG bona fides or the extent of their products' or practices' positive impact on the environment and society. Greenwashing has appeared as an enforcement priority on the agenda of the SEC's Division of Examinations since March 2021. And on May 25, 2022, the SEC released for notice and comment two proposed rules aimed squarely at the practice.