We welcome the work on the principles for climate-related financial risk management by the OCC, which recognizes the challenges faced by banks and supervisors alike in this area. However, our feedback outlines that principles-based guidance for supervisors and financial institutions will not be sufficient to achieve timely and impactful outcomes in managing climate-related financial risks of the banking sector.
In addition, further measures are needed based on a precautionary approach to tackling these risks, which can and should be done as part of a holistic review of bank prudential regulation.
Detailed points on addressing climate-related financial risks can be found in our recent report “silver bullet against green swans”.
