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Agency Filing

Agency FilingFinancial DisclosureFinancial Regulation

Comments to the SEC on Economic Analysis for Its Proposed Rule on Climate-Related Disclosures

In response to the Securities and Exchange Commission's proposed rule on climate-related disclosures, this letter commends the SEC for conducting an economic analysis that is consistent with relevant case law, and suggests some revisions that would provide additional context and support for the final analysis.
Lance Bowman, Jack Lienke, Bridget Pals, Alex Song, Michael Panfil, Noha Haggag, Stephanie Jones and Madison Condon
June 17, 2022
Agency FilingFinancial DisclosureFinancial Regulation

Comments to the SEC on Regulatory Precedents for Its Proposed Rule on Climate-Related Disclosures

In her dissent from the Securities and Exchange Commission's proposed rule on climate-related disclosures, Commissioner Peirce describes the SEC as “discover in a long-extant statute an unheralded power to regulate ‘a significant portion of the American economy’” and impermissibly transforming its regulatory role into that of a “Securities and Environment…
Lance Bowman, Jack Lienke, Bridget Pals, Alex Song, Michael Panfil, Noha Haggag, Stephanie Jones and Madison Condon
June 17, 2022
Adaptation as Risk ManagementAgency FilingEnvironmental JusticeFinancial DisclosureFinancial RegulationRegulatory ActivitiesRisk Management

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

These comments to the Federal Deposit Insurance Corporation (FDIC) support the FDIC's draft principles on banks' management of climate-related financial risks, and offer recommendations for the FDIC as it continues building on these principles with more detailed guidance. The comments recommend that the FDIC consider: (1) providing more detail on…
Stephanie Jones, Michael Panfil, Jack Lienke and Bridget Pals
June 3, 2022
Adaptation as Risk ManagementAgency FilingEnergy RegulationFederal Energy RegulationRisk Management

Comments to Federal Energy Regulatory Commission on Climate Impact Analysis in Natural Gas Project Reviews

These comments recommend that the Federal Energy Regulatory Commission (FERC) supplement its draft policy statement on natural gas project reviews with additional guidance on the evaluation of climate impacts on projects under the National Environmental Policy Act (NEPA). Holistic, specific, and actionable climate impact analysis is necessary to meet NEPA’s…
Michael Panfil and Stephanie Jones
April 25, 2022
Adaptation as Risk ManagementAgency FilingEnvironmental JusticeFinancial DisclosureFinancial RegulationRegulatory ActivitiesRisk Management

Comments to the OCC on Principles for Climate-Related Financial Risk Management for Large Banks

These comments to the Office of the Comptroller of the Currency (OCC) support the OCC's draft principles on banks' management of climate-related financial risks, and offer recommendations for the OCC as it continues building on these principles with more detailed guidance. The comments recommend that the OCC consider: (1) providing…
Stephanie Jones, Michael Panfil, Jack Lienke and Bridget Pals
February 14, 2022
Agency FilingEnvironmental JusticeRisk Management

Comments on Heat Injury and Illness Prevention in Outdoor and Indoor Work Settings (EDF, Institute for Policy Integrity)

These comments support an advance notice of proposed rulemaking by the Department of Labor's Occupational Safety & Health Administration (OSHA) as an important step in OSHA’s efforts to develop strong heat stress protections for workers. The comments recommend that OSHA consider climate change amplification of occupational heat risks and the…
Stephanie Jones, Jesse Hevia, Michael Panfil, Jack Lienke and Bridget Pals
January 26, 2022
Adaptation as Risk ManagementAgency FilingRisk Management

Comments to Federal Acquisition Regulatory Council on Minimizing the Risk of Climate Change in Federal Acquisitions

In the normal course of operation for federal procurement under the Federal Acquisition Regulation (FAR), care is taken to structure purchases and contracts consistent with principles of efficiency, risk management, and cost minimization. Existing procedures, however, do not yet incorporate and manage financial risks posed by the consequences of climate…
Noha Haggag and Michael Panfil
January 13, 2022
Agency FilingEnvironmental JusticeRisk Management

Comments on Heat Injury and Illness Prevention in Outdoor and Indoor Work Settings (Sabin Center)

These comments support an advance notice of proposed rulemaking by the Department of Labor's Occupational Safety & Health Administration (OSHA) on heat injury and illness prevention in outdoor and indoor work settings. The comments emphasize the importance of this initiative in combatting extreme heat, the most lethal climate disaster of…
Jacob Elkin
December 14, 2021
Agency FilingFinancial RegulationRegulatory Activities

Comments on Department of Labor Proposed Rule on Prudence and Loyalty in Selecting Plan Investments and Exercising Shareholder Rights

These comments support a Department of Labor proposed rule that clarifies that retirement plan fiduciaries should consider climate risk and other ESG factors whenever relevant to financial risk-return analysis for investment and proxy voting decisions. The comments additionally offer suggestions on potential improvements to the proposal for the Department's consideration.
Stephanie Jones, Michael Panfil, Sarah Ladin, Jack Lienke and Alex Song
December 13, 2021
Adaptation as Risk ManagementAgency FilingEnvironmental JusticeFinancial DisclosureFinancial RegulationPrivate GovernanceRisk Management

Comments to Federal Insurance Office on the Insurance Sector and Climate-Related Financial Risks

These comments make recommendations to the Treasury Department's Federal Insurance Office on how it can monitor, analyze, and address climate-related risks in the insurance industry.
Jack Lienke, Bridget Pals, Alex Song, Madison Condon, Michael Panfil, Stephanie Jones and Romany Webb
November 15, 2021