Skip to main content
Agency FilingRegulatory ActivitiesRisk Management

Comments on the CEQ’s NEPA Guidance on Consideration of GHG Emissions and Climate Change

These comments offer support and provide recommendations for the adoption of CEQ’s interim guidance, which will improve federal decision-making by ensuring that federal agencies fully and accurately account for climate change in environmental reviews as legally required under the National Environmental Policy Act.
Agency FilingRegulatory Activities

Comments on the CEQ’s NEPA Guidance on Consideration of GHG Emissions and Climate Change

These comments offer support and provide recommendations for the adoption of CEQ's interim guidance, which will improve federal decision-making by ensuring that federal agencies fully and accurately account for climate change in environmental reviews as legally required under the National Environmental Policy Act.
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.…
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…
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,…
Agency FilingFinancial Regulation

Comments to the FIO on Climate-Related Financial Risk Data Collection

These comments support the Federal Insurance Office's proposal to collect information from property and casualty insurers regarding current and historical underwriting data on homeowners' insurance. This data collection would mark a critical step towards understanding how climate-related disasters may affect the availability and affordability of insurance for U.S. householders. This…
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…
Agency FilingEnergy RegulationFederal Energy Regulation

Comments to FERC on One-Time Informational Reports on Extreme Weather Vulnerability Assessments

In these comments, EDF and the Sabin Center support the Commission’s proposal to require transmission providers to file one-time informational reports describing their current or planned policies and processes for conducting extreme weather vulnerability assessments. In promulgating a final rule, EDF and the Sabin Center recommend that the Commission supplement…
Agency FilingFinancial DisclosureFinancial Regulation

Comments to the SEC on Fund ESG Disclosures (Policy Integrity)

The SEC has proposed a series of new disclosures for investment companies regarding their Environmental, Social, and Governance (ESG) activities. These disclosures would reduce "greenwashing" - a practice where companies misrepresent the sustainability of their investments in order to advertise to investors looking to invest in green funds - by…