FSOC and Federal Banking Agencies Move on Climate Change

26 October 2021
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Key takeaways:
  • On October 21, 2021, the Financial Stability Oversight Council (“FSOC”) released its Report on Climate-Related Financial Risk (the “Report”). The Report assesses climate-related risks to U.S. financial stability, describes current impediments to addressing climate-related financial risks and proposes nonbinding recommendations to FSOC member agencies to address climate-related financial risk.
  • The Report was issued as federal banking regulators are focusing on climate-related initiatives and potential regulations to a much greater extent. It also comprises part of President Biden’s “whole-of-government” approach to climate change.
  • The Report recommends that FSOC member agencies use their existing authorities to address climate-related financial risks in four key areas: (1) building capacity and expanding efforts; (2) filling climate-related data and methodological gaps; (3) enhancing public climate-related disclosures, and (4) assessing and mitigating climate-related risks to financial stability, such as by conducting scenario analyses.