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On January 17, 2023, the Board of Governors of the Federal Reserve System (“Federal Reserve”) launched its pilot climate scenario analysis exercise (“CSA”) by publishing instructions for the six US banking organizations that will participate.

As part of the CSA, participating organizations will submit data templates, supporting documentation, and responses to qualitative questions to the

In January 2023, the Board of Governors of the Federal Reserve System released a report that reviews the climate action plans of global systemically important banks (“G-SIBs”) and summarizes the progress they are making toward achieving them (“Climate Action Report”).[1] As discussed below, the Climate Action Report can be an useful tool for banks that are developing sustainable financing products and climate risk management processes because it identifies key peer behaviors and widely used resources.

Continue Reading Climate Action and Banks: Review of Climate Action Plans Released by US Federal Reserve

On December 8, 2022, the Basel Committee on Banking Supervision (“BCBS”) released guidance to clarify how climate-related financial risks may be captured in existing capital and liquidity requirements for banking organizations (“Climate FAQs”). The Climate FAQs are noteworthy because they indicate that standard setters believe climate-related financial risks should be included in bank capital requirements

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

On June 2, 2022, the US Commodity Futures Trading Commission (“CFTC”) released a request for information on how climate-related financial risk is related to the derivatives markets and underlying commodities markets (the “RFI”). The RFI is intended to inform the CFTC’s next steps in this rapidly developing area and respond to the 2021 Report on Climate-Related

On March 21, 2022, the U.S. Securities and Exchange Commission (SEC) voted 3:1, with only Commissioner Hester Peirce dissenting, to propose long-awaited rules that, if adopted, would require extensive reporting by public companies of climate change-related disclosure and related attestation (the “Proposal”). Comments on the Proposal are due 30 days after

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

On November 8, 2021, the acting head of the Office of the Comptroller of the Currency (OCC), Michael J. Hsu, issued a call to action on climate change to the boards of directors of OCC-regulated banks. Specifically, he outlined an initial series of climate change-related questions that boards should be asking bank management

On October 21, 2021, the United States Financial Stability Oversight Council (FSOC) released its 133-page report on Climate-Related Financial Risk (Report) and related Factsheet. The Report discusses how climate-related financial risks can implicate financial stability and declares climate-related finance risk as an emerging threat to financial stability. In a new