The Securities Industry and Financial Markets Association (“SIFMA”) recently filed a lawsuit against the Missouri Secretary of State, Jay Ashcroft, in U.S. District Court. This legal dispute is a result of new rules, which target broker-dealers and investment advisers for so-called “woke” investing, specifically using Environmental, Social, or Governance criteria (“ESG”) or other non-financial objectives (e.g., Bibically Responsible Investing, Halal Investing).