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Agency FilingFinancial RegulationRisk Management

Comments to the CFTC on Potential Regulatory Amendments Governing Risk Management Programs

These comments support the CFTC’s intention to update its risk management program regulations, and in particular urge the CFTC to ensure that such programs adequately account for climate-related financial risks. The ANPRM asks whether the CFTC should consider enumerating climate-related financial risk in the risk management program regulations. Whether through…
Cynthia Hanawalt
September 18, 2023
Blog/News ArticleFinancial DisclosureFinancial RegulationRegulatory Activities

Global Consensus is Emerging on Corporate Scope 3 Disclosures. Will the SEC Lead or Lag?

2023 is a significant year for corporate climate disclosure rules: regulators around the world are issuing or strengthening their disclosure requirements for registered companies pertaining to sustainability and climate-related financial risk. In Europe, the European Commission plans to finalize initial reporting standards for corporate sustainability reporting by June. UK regulators…
Cynthia Hanawalt
March 28, 2023
Agency FilingFinancial RegulationRegulatory Activities

Comments on the New York State Department of Financial Services’ Proposed Guidance for New York State Regulated Banking and Mortgage Institutions Relating to Management of Material Financial Risks from Climate Change, December 2022

The Sabin Center supports the Proposed Guidance as a valuable step in DFS’ effort to ensure its regulated institutions integrate climate-related financial risks into their risk management frameworks. In light of the urgency of the climate crisis, the timeline for implementation of the Proposed Guidance should be expeditious and concrete.…
Cynthia Hanawalt
March 20, 2023
Agency FilingFinancial DisclosureFinancial RegulationRegulatory Activities

Comments to the FAR on the Disclosure of Greenhouse Gas Emissions and Climate-Related Financial Risk

These comments support the Federal Acquisition Regulatory Council's proposed rule on the disclosure of greenhouse gas emissions and climate-related financial risk. The Proposed Rule is an important step to safeguarding and promoting efficient and economical procurement, and ensuring resilience of essential government functions in light of escalating climate-related financial and…
Cynthia Hanawalt
February 13, 2023
Blog/News ArticleFinancial RegulationRegulatory Activities

DOL Rule Clarifies That ESG Analysis Is Consistent With Fiduciary Duty. Will It Preempt State Anti-ESG Laws?

This blog discusses the Department of Labor's final rule that was issued on Tuesday, November 22, that allows for plan fiduciaries to consider climate change and other environmental, social, and governance (ESG) characteristics when they choose investments and exercise shareholder rights, reversing a Trump-era rule that sought to constrain this…
Cynthia Hanawalt
November 23, 2022