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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…
Agency FilingFinancial DisclosureFinancial Regulation

Comments to the ISSB on Climate-Related Disclosures Exposure Draft

These comments support the Climate-Related Disclosures Exposure Draft of the International Sustainability Standards Board (ISSB), which will provide investors around the globe with the information necessary to inform their investment decisions. The comments commend the ISSB’s goal of creating a global baseline and encourage the ISSB to consider certain modifications…