The National Credit Union Administration (“NCUA”) has requested comment (the “RFI”) on how climate and natural disaster risks may affect federally insured credit unions, their members, and the National Credit Union Share Insurance Fund. The RFI indicates that the NCUA may use the results of the RFI to develop regulatory and reporting requirements and supervisory expectations for credit union management of climate-related financial risks. While it does not foreshadow the specific contours of these obligations, credit unions should look at the actions of the federal banking regulators, New York Department of Financial Services, and Task Force on Climate-related Financial Disclosures as examples of what the NCUA might impose.

The NCUA will accept responses to the RFI through June 26, 2023.

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