Ladies and Gentlemen:
The Bank Policy Institute[1] appreciates the opportunity to comment on the Board of Governors of the Federal Reserve System’s draft Statement of Principles for Climate-Related Financial Risk Management for Large Financial Institutions (“FRB Proposal”),[2] which aims to support the identification and management of climate-related financial risks at FRB-regulated financial institutions with more than $100 billion in total consolidated assets.
BPI supports the FRB’s efforts to develop and articulate principles-based guidance for climate- related financial risk management, which 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.
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[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] FRB, Statement of Principles for Climate-Related Financial Risk Management for Large Financial Institutions, 87 Fed. Reg. 75267 (December 8, 2022).
