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Agency FilingFinancial RegulationRisk Management

Comments to the CFTC on Potential Regulatory Amendments Governing Risk Management Programs

These comments support the CFTC’s intention to update its risk management program regulations, and in particular urge the CFTC to ensure that such programs adequately account for climate-related financial risks. The ANPRM asks whether the CFTC should consider enumerating climate-related financial risk in the risk management program regulations. Whether through…
Jeffrey Fralick, Gabrielle Stephens, Stephanie Jones and Cynthia Hanawalt
September 18, 2023
Agency FilingFinancial RegulationRisk Management

Comments on the NCUA’s Request for Information on Climate-Related Financial Risk

These comments were submitted to the NCUA in response to its request for information on current and future climate and natural disaster risks to federally insured credit unions, related entities, their members, and the National Credit Union Share Insurance Fund. EDF and IPI support the NCUA's intention to promote safety…
Michael Panfil, Stephanie Jones, Gabrielle Stephens and Jack Lienke
June 26, 2023
Agency FilingRegulatory ActivitiesRisk Management

Comments on the CEQ’s NEPA Guidance on Consideration of GHG Emissions and Climate Change

These comments offer support and provide recommendations for the adoption of CEQ’s interim guidance, which will improve federal decision-making by ensuring that federal agencies fully and accurately account for climate change in environmental reviews as legally required under the National Environmental Policy Act.
Dena Adler, Soorim Song, Max Sarinsky and Nika Sabasteanski
April 10, 2023
Agency FilingRegulatory Activities

Comments on the CEQ’s NEPA Guidance on Consideration of GHG Emissions and Climate Change

These comments offer support and provide recommendations for the adoption of CEQ's interim guidance, which will improve federal decision-making by ensuring that federal agencies fully and accurately account for climate change in environmental reviews as legally required under the National Environmental Policy Act.
Eleonor Dyan Garcia, Romany Webb and Jessica Wentz
April 10, 2023
Agency FilingFinancial RegulationRegulatory Activities

Comments on the New York State Department of Financial Services’ Proposed Guidance for New York State Regulated Banking and Mortgage Institutions Relating to Management of Material Financial Risks from Climate Change, December 2022

The Sabin Center supports the Proposed Guidance as a valuable step in DFS’ effort to ensure its regulated institutions integrate climate-related financial risks into their risk management frameworks. In light of the urgency of the climate crisis, the timeline for implementation of the Proposed Guidance should be expeditious and concrete.…
Eleonor Dyan Garcia and Cynthia Hanawalt
March 20, 2023
Agency FilingFinancial DisclosureFinancial RegulationRegulatory Activities

Comments to the FAR on the Disclosure of Greenhouse Gas Emissions and Climate-Related Financial Risk (IPI)

These comments provide observations and recommendations to the Federal Acquisition Regulation Council regarding its proposal to require certain Federal contractors to disclose greenhouse gas emissions and climate-related financial risk and to set science-based targets to reduce their greenhouse gas emissions.
Jack Lienke and Derek Sylvan
February 13, 2023
Agency FilingFinancial DisclosureFinancial RegulationRegulatory Activities

Comments to the FAR on the Disclosure of Greenhouse Gas Emissions and Climate-Related Financial Risk

These comments support the Federal Acquisition Regulatory Council's proposed rule on the disclosure of greenhouse gas emissions and climate-related financial risk. The Proposed Rule is an important step to safeguarding and promoting efficient and economical procurement, and ensuring resilience of essential government functions in light of escalating climate-related financial and…
Jeffrey Fralick, Stephanie Jones, Michael Panfil, Romany Webb, Cynthia Hanawalt, Eleonor Dyan Garcia and Megan Herzog
February 13, 2023
Agency FilingFinancial DisclosureRegulatory Activities

Comments to the Federal Reserve on Principles for Climate-Related Financial Risk Management for Large Financial Institutions

These comments support the Draft Principles as an important step in the Board’s efforts to guide banks to update their risk management practices as needed in light of climate-related financial risks, thereby promoting safety and soundness. We recommend that the Board continue building upon these Draft Principles with final guidance,…
Jack Lienke, Stephanie Jones, Michael Panfil and Gabrielle Stephens
February 6, 2023
Agency FilingFinancial Regulation

Comments to the FIO on Climate-Related Financial Risk Data Collection

These comments support the Federal Insurance Office's proposal to collect information from property and casualty insurers regarding current and historical underwriting data on homeowners' insurance. This data collection would mark a critical step towards understanding how climate-related disasters may affect the availability and affordability of insurance for U.S. householders. This…
Stephanie Jones, Michael Panfil, Karina French and Jeffrey Fralick
December 20, 2022