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On January 27, 2021, the United Kingdom’s Department for Work and Pensions (“DWP”) issued the draft regulation, The Occupational Pension Schemes (Climate Change Governance and Reporting) Regulations 2021 (the “Regulation”). The Regulation has been submitted for approval by Parliament and, assuming it is approved, would take effect on October 1, 2021. While pension plans in the United States are currently limited by a recent labor regulation to taking non-pecuniary environmental factors into account as a “tie-breaker” after considering pecuniary factors (which may also include environmental factors to the extent they are expected to materially influence the investment performance of a plan investment), and cannot take nonpecuniary factors into account at all in default funds, UK pension schemes (i.e., pension plans, DB and DC) with more than £5 billion in assets (initially, with the threshold dropping to £1