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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.…
Eleonor Dyan Garcia
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…
Eleonor Dyan Garcia
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…
Eleonor Dyan Garcia
November 23, 2022
Agency FilingFinancial DisclosureFinancial Regulation

Comments to the CFTC on Climate-Related Financial Risk (Sabin Center)

These comments strongly support the Commodity Futures Trading Commission's ("Commission") efforts to respond to the financial consequences of climate change and highlight the legal basis for appropriate rule-making to address these risks. Regulations to address climate risk are consistent with the Commission's mandate to ensure the integrity of transactions under…
Eleonor Dyan Garcia
October 7, 2022