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Organizations Involved: Environmental Defense Fund, Sabin Center
Source: Commodity Futures Trading Commission


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 regulation or guidance, the CFTC should make clear that climate-related financial risk has significant and increasing implications for the derivatives market, which market participants should assess and manage.

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