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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
Financial RegulationRegulatory ActivitiesReport

Public Comments Overwhelmingly Support the US Labor Department Proposed Rule Addressing the Inclusion of ESG Criteria and Proxy Voting in ERISA-Governed Retirement Plans

This analysis of public comments found overwhelming support for the Department of Labor's proposed rule Prudence and Loyalty in Selecting Plan Investments and Exercising Shareholder Rights, with 97 percent of comments in favor. The proposed rule affirms the ability of retirement plan fiduciaries to consider climate risk and other environmental,…
Eric Pitt, Bryan McGannon, Ginny Brooks, Gabriel Malek, Stephanie Jones and Claire Staib-Kaufman
January 25, 2022
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