If yes, describe how you typically incorporate E, S, and G factors into the reporting.
The Ethics Metrics model integrates and applies the OECD Principles of Corporate Governance by measuring and rating the degree to which the quarterly financial performance of large U.S. Bank or Depository Institution Holding Companies either comply with sound governance, including compliance with the Code of Ethics under Sarbanes Oxley and related banking and securities laws or violate the foregoing laws and regulations and fail to disclose these events as potential securities and accounting fraud. These are the same standards the Federal Reserve is required to monitor and supervise, effective 2010, based on the Dodd Frank Act and 12 U.S.C. § 1844(c)(1)(A). The resulting output is categorized into a range of Ethics Metrics Credit Ratings on a scale of 1 to 9. Ratings of 1 and 2 qualify as sound governance, ethical conduct and compliance with safe and sound banking practices and securities laws. Ratings of 3 to 9 qualify as increasing levels of compliance violations and undisclosed material contracts on formal enforcement actions that represent potential fraud, danger of default, default, systemic risk, and bankruptcy or orderly liquidation.