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Agency FilingFinancial RegulationRisk Management

Comments to the CFTC on Potential Regulatory Amendments Governing Risk Management Programs

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 climate-related financial risks. The ANPRM asks whether the CFTC should consider enumerating climate-related financial risk in the risk management program regulations. Whether through…
Agency FilingFinancial RegulationRisk Management

Comments on the NCUA’s Request for Information on Climate-Related Financial Risk

These comments were submitted to the NCUA in response to its request for information on current and future climate and natural disaster risks to federally insured credit unions, related entities, their members, and the National Credit Union Share Insurance Fund. EDF and IPI support the NCUA's intention to promote safety…
Event/ConferenceFinancial RegulationRegulatory ActivitiesRisk Management

Testimony of Carolyn Kousky on Reauthorization and Reform of the National Flood Insurance Program

This testimony from a Senate Committee on Banking, Housing, and Urban Affairs hearing the reauthorization and reform of the National Flood Insurance Program (NFIP) highlights the ways in which the NFIP can improve community resilience to climate change and extreme weather events. Flood insurance has a critical role to play…
Carolyn Kousky
May 2, 2023
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.
ReportRisk Management

Catastrophe Bonds

Catastrophe bonds are the most well-known type of ILS to transfer catastrophe risk to capital market investors and the second-largest according to volume. The first catastrophe bonds were issued in the mid-1990s and the market has been steadily growing since that time. This primer explains the general mechanics of catastrophe…
Carolyn Kousky
September 20, 2022
ReportRisk Management

Parametric Insurance for Disasters

The concept of parametric insurance, while not new, is getting increased attention as a way to provide faster and more flexible funds to victims of disasters and as a tool to provide post-disaster funds for emerging and otherwise difficult-to-insure risks. There is also hope that parametric policies can broaden disaster…
Carolyn Kousky
September 20, 2022
Financial RegulationRisk ManagementSummary Document

Summary Report: Workshop on Physical Climate Risk and the United States Financial System

In May 2022, CarbonPlan, the Environmental Defense Fund (EDF), and the Initiative on Climate Risk and Resilience Law (ICRRL) co-convened a Chatham House Rule workshop to better understand how climate science is used in risk assessment and decision-making across the financial sector. Pursuant to the rule, the meeting organizers and…
Adaptation as Risk ManagementBlog/News ArticleEnergy RegulationRisk ManagementState Energy Regulation

Announcing the Electric Resilience Toolkit

This blog introduces the Electric Resilience Toolkit, a platform designed to provide engagement-focused information for use directly in regulatory proceedings to support well-designed climate resilience planning by electric utilities. The toolkit is available at: