On June 23, 2022, the American Bankers Association and 51 state bankers associations released a letter to the federal financial regulators that describes principles the regulators should use when developing guidance and regulations on ESG issues (“Industry Letter”). These principles reflect the industry’s view on how the government can maintain a free-market financial system that also
FHFA’s Strategic Plan Adds Focus on Climate Change
On February 9, 2022, the U.S. Federal Housing Finance Agency (“FHFA”) released its Draft FHFA Strategic Plan: Fiscal Years 2022-2026 (the “2022 Strategic Plan”) for public input.
This year, FHFA added a novel objective to this plan – to identify options for incorporating climate change into FHFA’s governance of the entities it regulates.
According to FHFA Acting Director Sandra L. Thompson, the 2022 Strategic Plan provides a roadmap for FHFA to promote sustainable and equitable access to mortgage credit and protect the safety and soundness of the U.S. housing system. While not a statutory requirement, the FHFA uses its strategic planning process to set priorities based on important stakeholder input. Typically, FHFA releases a strategic plan every few years, outlining the agency’s priorities for the supervision and regulation of the Federal Home Loan Banks, and of Fannie Mae and Freddie Mac (the “Enterprises”). The agency sets forth those priorities through strategic goals and objectives to achieve those goals.…
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FHFA Releases Statement on Climate Change
Climate change is a serious threat to the US housing finance system. That is the conclusion reached by the Federal Housing Finance Agency (“FHFA”) in a December 27th statement. In the statement, Acting FHFA Director Sandra L. Thompson recognizes that Fannie Mae, Freddie Mac, and the Federal Home Loan Banks have an important leadership role…
Climate-Related Risk Management Principles Released by US Banking Regulator
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…
Climate Change Impacts to the US Mortgage Industry
Climate change could have serious impacts on the mortgage industry, and stakeholders should take action now. That is the recent urgent message from federal regulators and mortgage industry stakeholders.
Recent reports and initiatives from the Mortgage Bankers Association’s Research Institute for Housing America, the White House, the Departments of Housing and Urban Development, Veterans Affairs…
Update on FHFA’s Request for Input on Climate Change and Natural Disaster Risks
Earlier this year, the US Federal Housing Finance Agency (“FHFA”) issued a Request for Input (“RFI”) on the risks of climate change and natural disasters to the national housing finance markets.1 As we discussed in our prior Legal Update, the RFI posed 25 questions on how FHFA can best identify, assess and respond to those risks for the entities FHFA regulates (Fannie Mae, Freddie Mac and the Federal Home Loan Banks) and the housing finance markets in general. Comments were due on April 19, 2021. The RFI is one of a series of recent actions by the federal government to address the financial risks posed by climate change.2 Most recently, on May 20, 2021, President Biden issued an executive order requiring the federal government to take several actions to identify and address the financial risks posed by climate change.3
Continue reading for our discussion on the comments in response to the RFI.…
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