Organizations Involved: Initiative on Climate Risk and Resilience Law, Environmental Defense Fund, Institute for Policy Integrity
Source: Office of the Comptroller of the Currency

Abstract

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 more detail on the physical and transition risks that affect management of various risk areas; (2) guiding banks on use of climate-related data; (3) requiring banks to incorporate climate risk into regulatory reports; (4) defining certain scenarios and accounting for correlated risks in scenario analysis; and (5) mitigating potential harm to disadvantaged communities from banks’ climate risk management strategies.

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