Last summer we wrote about how public comments for federal actions really make a difference, and how if you care about climate and air pollution, this is a real way to take meaningful action. Federal agencies are required by law to consider and respond to ALL public comments – and every comment you make on a proposed federal rule really makes a difference for health, for clean air, for climate.
Most of the time, federal climate actions are with EPA and agencies with environmental or transportation related issues.
Right now, there is a federal banking agency asking for public comment about banks and climate change. The Office of the Comptroller of Currency, which oversees and provides guidance to banks, has proposed new guidance to banks that gives guidelines on how banks include threats from climate change into their risk management, planning, and governance. It means they should include risks from climate change when they do business.
Here is what is in the proposed new guidance for banks (information from Public Citizen):
– The new guidance is for banks with $100 billion or more in assets.
– The guidance recognizes that climate change can threaten our country’s financial stability, and states that all aspects of bank business need to join in managing climate related financial risk.
– The guidance acknowledges that climate risk is higher for communities of color and low income communities, who are more vulnerable because of our country’s environmental racism and discriminatory lending practices. Communities that have the highest climate vulnerability will need the most help building resilience, and the guidance addresses the higher need and gives guidance for not discriminating. The guidance includes standards about disparate impacts and fair lending practices, to be sure there isn’t intentional or unintentional impact on communities of color and other vulnerable communities.
– The guidance says banks need to look at long term financial impacts of climate change, not just the usual 3-5 years that banks typically consider.
– The guidance will hold banks accountable, making sure that their actions and investments match their public statements and commitments.
What is the Office of the Comptroller of Currency (OCC)? It is part of the Department of Treasury and was established by the National Currency Act of 1863. The OCC approves or denies new banks, new branches, capital and other banking activities and structure. It makes sure banks are complying with laws and regulations, and can remove bank officers or directors. For more information about the OCC, read this article in Investopedia.
For more information about the new proposed bank guidance, read this article by Public Citizen.
01/20/2022
