To Whom It May Concern: Environmental Defense Fund, the Institute for Policy Integrity at NYU School of Law, and the Initiative on Climate Risk and Resilience Law respectfully submit the attached comments to the Office of the Comptroller of the Currency in response to its request for feedback regarding its Principles for Climate-Related Financial Risk Management for Large Banks, published on December 16, 2021 (OCC Bulletin 2021-62, Docket No. OCC-2021-0023). Respectfully submitted, /s/ Stephanie Jones Stephanie Jones Michael Panfil Environmental Defense Fund sjones@edf.org mpanfil@edf.org /s/ Jack Lienke Jack Lienke Bridget Pals Institute for Policy Integrity at New York University School of Law jack.lienke@nyu.edu bridget.pals@nyu.edu Attachment (1): Environmental Defense Fund, Institute for Policy Integrity at NYU School of Law & Initiative on Climate Risk and Resilience Law, Comments to the Office of the Comptroller of the Currency on Principles for Climate-Related Financial Risk Management for Large Banks (Feb. 14, 2022)
Principles for Climate-Related Financial Risk Management for Large Banks
Activity
Environmental Defense Fund filed 1 comment on this docket between Feb 18, 2022 and Feb 18, 2022. 20 other organizations filed here. The comment window closed 1625d ago.
What Environmental Defense Fund filed (1)
Abstract
The draft Principles for Climate-Related Financial Risk Management for Large Banks are designed to support the identification and management of climate-related financial risks by OCC-supervised banks with more than $100 billion in total consolidated assets. The principles are intended to support banks’ efforts to focus on key aspects of climate-related financial risk management and provide a high-level framework for climate-related financial risk management consistent with existing OCC rules and guidance. The OCC is seeking feedback on all aspects of these draft principles. It will use this feedback to inform any future guidance on climate-related financial risk.
View on regulations.gov →Co-filers (20)
See everyone who commented →- Environmental Defense FundTHIS ORG1 filing · confidence 97%
- American Council on Renewable Energytrade assoc.1 filing · confidence 85%
- American Friends Service Committeetrade assoc.1 filing · confidence 85%
- Bank Policy Institutetrade assoc.1 filing · confidence 97%
- California Reinvestment Coalitiontrade assoc.1 filing · confidence 85%
- City National Bankunverified attribution1 filing · confidence 70%
- Consumer Federation of Americatrade assoc.1 filing · confidence 85%
- GeoDataVision LLCunverified attribution1 filing · confidence 70%
- GeoDataVision LLC 2unverified attribution1 filing · confidence 70%
- Inc. and Securities Industry and Financial Markets Associationtrade assoc.1 filing · confidence 85%
- Institute of International Bankerstrade assoc.1 filing · confidence 85%
- Institute of International Financetrade assoc.1 filing · confidence 85%
- Japanese Bankers Associationtrade assoc.1 filing · confidence 85%
- Moody's Corporationunverified attribution1 filing · confidence 70%
- Mortgage Bankers Associationtrade assoc.1 filing · confidence 97%
- MSCI Inc.unverified attribution1 filing · confidence 70%
- Natural Resources Defense Council (NRDC)trade assoc.1 filing · confidence 97%
- The Institute of Internal Auditorstrade assoc.1 filing · confidence 85%
- The Ohio Bankers Leaguetrade assoc.1 filing · confidence 85%
- The Risk Management Associationtrade assoc.1 filing · confidence 85%
- U.S. Chamber of Commerce1 filing · confidence 97%