On December 16, 2021, the US Office of the Comptroller of the Currency (OCC) released draft principles for managing exposures to climate-related financial risks (Climate Principles). The OCC regulates national banks, federal savings associations, and federal branches and agencies of foreign banking organizations.

The Climate Principles are targeted at banks with over $100 billion in total assets that are regulated by the OCC. The OCC will accept comments on the Climate Principles until February 14, 2022, and expects to issue more detailed guidance on climate risk management throughout 2022. In a new Legal Update, we provide background on the OCC’s climate risk management initiative and discuss the Climate Principles.

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