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Regulatory Activities

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
Blog/News ArticleFinancial RegulationRegulatory Activities

DOL Rule Clarifies That ESG Analysis Is Consistent With Fiduciary Duty. Will It Preempt State Anti-ESG Laws?

This blog discusses the Department of Labor's final rule that was issued on Tuesday, November 22, that allows for plan fiduciaries to consider climate change and other environmental, social, and governance (ESG) characteristics when they choose investments and exercise shareholder rights, reversing a Trump-era rule that sought to constrain this…
Cynthia Hanawalt and Eleonor Dyan Garcia
November 23, 2022
Adaptation as Risk ManagementAgency FilingEnvironmental JusticeFinancial DisclosureFinancial RegulationRegulatory ActivitiesRisk Management

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

These comments to the Federal Deposit Insurance Corporation (FDIC) support the FDIC's draft principles on banks' management of climate-related financial risks, and offer recommendations for the FDIC as it continues building on these principles with more detailed guidance. The comments recommend that the FDIC consider: (1) providing more detail on…
Stephanie Jones, Michael Panfil, Jack Lienke and Bridget Pals
June 3, 2022
Blog/News ArticleFinancial RegulationRegulatory Activities

How a Proposed Department of Labor Rule Would Help Protect Retirement Savings From Climate Risk

This blog explains how a Department of Labor proposal would help protect Americans’ retirement savings by highlighting the financial relevance of climate change; undoing harmful Trump administration rules; affirming that fiduciaries should consider ESG factors like climate change when relevant to investment risk-return analysis; applying the same rational principles to…
Stephanie Jones and Alex Song
March 14, 2022
Adaptation as Risk ManagementAgency FilingEnvironmental JusticeFinancial DisclosureFinancial RegulationRegulatory ActivitiesRisk Management

Comments to the OCC on Principles for Climate-Related Financial Risk Management for Large Banks

These comments to the Office of the Comptroller of the Currency (OCC) support the OCC's draft principles on banks' management of climate-related financial risks, and offer recommendations for the OCC as it continues building on these principles with more detailed guidance. The comments recommend that the OCC consider: (1) providing…
Stephanie Jones, Michael Panfil, Jack Lienke and Bridget Pals
February 14, 2022
Financial RegulationRegulatory ActivitiesReport

Public Comments Overwhelmingly Support the US Labor Department Proposed Rule Addressing the Inclusion of ESG Criteria and Proxy Voting in ERISA-Governed Retirement Plans

This analysis of public comments found overwhelming support for the Department of Labor's proposed rule Prudence and Loyalty in Selecting Plan Investments and Exercising Shareholder Rights, with 97 percent of comments in favor. The proposed rule affirms the ability of retirement plan fiduciaries to consider climate risk and other environmental,…
Eric Pitt, Bryan McGannon, Ginny Brooks, Gabriel Malek, Stephanie Jones and Claire Staib-Kaufman
January 25, 2022
Agency FilingFinancial RegulationRegulatory Activities

Comments on Department of Labor Proposed Rule on Prudence and Loyalty in Selecting Plan Investments and Exercising Shareholder Rights

These comments support a Department of Labor proposed rule that clarifies that retirement plan fiduciaries should consider climate risk and other ESG factors whenever relevant to financial risk-return analysis for investment and proxy voting decisions. The comments additionally offer suggestions on potential improvements to the proposal for the Department's consideration.
Stephanie Jones, Michael Panfil, Sarah Ladin, Jack Lienke and Alex Song
December 13, 2021