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Agency FilingFinancial RegulationRisk Management

Comments to the CFTC on Potential Regulatory Amendments Governing the Risk Management Programs of Swap Dealers, Major Swap Participants, and Futures Commission Merchants

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 climaterelated financial risks. The ANPRM asks whether the CFTC should consider enumerating climate-related financial risk in the risk management program regulations.2 Whether through…
Gabrielle Stephens
September 18, 2023
Agency FilingFinancial DisclosureRegulatory Activities

Comments to the Federal Reserve on Principles for Climate-Related Financial Risk Management for Large Financial Institutions

These comments support the Draft Principles as an important step in the Board’s efforts to guide banks to update their risk management practices as needed in light of climate-related financial risks, thereby promoting safety and soundness. We recommend that the Board continue building upon these Draft Principles with final guidance,…
Gabrielle Stephens
February 6, 2023