BPI Comments on FDIC Climate-Related Financial Risk Management Proposal for Large Financial Institutions

Ladies and Gentlemen:

The Bank Policy Institute[1] appreciates the opportunity to comment on the Federal Deposit Insurance Corporation’s draft Statement of Principles for Climate-Related Financial Risk Management for Large Financial Institutions (“FDIC Proposal”)[2] which aims to support the identification and management of climate-related financial risks at FDIC-regulated financial institutions with more than $100 billion in total consolidated assets.

BPI supports the FDIC’s efforts to develop and articulate principles-based guidance for climate- related financial risk management, which we believe can be helpful to both financial institutions and supervisors as they work to ensure that financial institutions identify and manage the possible manifestations of physical- and transition-related risks of climate change on their businesses and operations. Our members are actively evaluating climate-related financial risks and their potential impacts and are devoting substantial resources to developing risk management capabilities to identify, measure, and mitigate these risks.

To read the full comment letter, click here, or click on the download button below.

[1] The Bank Policy Institute is a nonpartisan public policy, research and advocacy group, representing the nation’s leading banks and their customers. Our members include universal banks, regional banks and the major foreign banks doing business in the United States. Collectively, they employ almost 2 million Americans, make nearly half of the nation’s small business loans, and are an engine for financial innovation and economic growth.

[2] FDIC, Statement of Principles for Climate-Related Financial Risk Management for Large Financial Institutions, 87 Fed. Reg. 19507 (April 4, 2022).