Ladies and Gentlemen:
The Bank Policy Institute[1] appreciates the opportunity to provide further feedback to the California Air Resources Board regarding its implementation of California Senate Bill 253 (2023) and Senate Bill 261 (2023), each as amended by Senate Bill 219 (2024). This comment letter supplements our prior comment letters on this topic and focuses on the proposed rulemaking concepts for CARB’s subsequent regulation implementing SB 253 reporting requirements applicable beginning in 2027 (the “Subsequent Regulation”), which were discussed at CARB’s July 21, 2026 public workshop.[2]
To read the full comment letter, please click here, or click on the download button below.
[1] The Bank Policy Institute is a nonpartisan public policy, research and advocacy group that represents universal banks, regional banks, and the major foreign banks doing business in the United States. The Institute produces academic research and analysis on regulatory and monetary policy topics, analyzes and comments on proposed regulations, and represents the financial services industry with respect to cybersecurity, fraud, and other information security issues.
[2] See CARB, SB 253 Public Workshop: California Corporate Greenhouse Gas Reporting Program (July 21, 2026), at 11, available at https://ww2.arb.ca.gov/sites/default/files/2026-07/SB_253_Presentation_July_2026.pdf (the “July Public Workshop.”). BPI previously submitted several comment letters on CARB’s implementation of SB 253 and SB 261 (as amended and collectively, the “climate laws”). See BPI, Information Solicitation to Inform Implementation of California Climate Disclosure Legislation: Senate Bills 253 and 261, as amended by SB 219 (Mar. 21, 2025), available at https://bpi.com/wp-content/uploads/2025/03/BPI-CARB-Comment-Letter-March-2025.pdf; BPI, SB 253/261/219 Public Workshop: Regulation Development and Additional Guidance (August 21, 2025), available at https://bpi.com/wp-content/uploads/2025/09/BPI-CARB-Comment-Letter-September-2025.pdf; BPI, Proposed California Corporate Greenhouse Gas Reporting and Climate-Related Financial Risk Disclosure Initial Regulation, available at https://bpi.com/wp-content/uploads/2026/02/BPI-Comments-on-Californias-Climate-Reporting-Initial-Regulation.pdf; and BPI, SB 253 Public Workshop: California Corporate Greenhouse Gas Reporting Program (March 23, 2026), available at https://bpi.com/wp-content/uploads/2026/04/BPI-CARB-Comment-Letter-April-2026.pdf.BPI recognizes that there is ongoing litigation regarding the climate laws. BPI is submitting this letter to be responsive to CARB’s solicitation for public comments on its public workshop and is not expressing any view on the litigation. In addition, this letter does not take a position on or otherwise waive potential arguments relating to the authority of a state regulator to require reporting of information and payment of a fee in connection with such reporting from a national bank under applicable law, including 12 U.S.C. § 484.
