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Regulator & Court Approaches to Managing Uncertainty in the Climate Risk Context

Event/ConferenceFinancial RegulationRegulatory ActivitiesRisk Management

Testimony of Carolyn Kousky on Reauthorization and Reform of the National Flood Insurance Program

This testimony from a Senate Committee on Banking, Housing, and Urban Affairs hearing the reauthorization and reform of the National Flood Insurance Program (NFIP) highlights the ways in which the NFIP can improve community resilience to climate change and extreme weather events. Flood insurance has a critical role to play…
Carolyn Kousky
May 2, 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
Blog/News ArticleFinancial DisclosureFinancial RegulationRegulatory Activities

Global Consensus is Emerging on Corporate Scope 3 Disclosures. Will the SEC Lead or Lag?

2023 is a significant year for corporate climate disclosure rules: regulators around the world are issuing or strengthening their disclosure requirements for registered companies pertaining to sustainability and climate-related financial risk. In Europe, the European Commission plans to finalize initial reporting standards for corporate sustainability reporting by June. UK regulators…
Cynthia Hanawalt
March 28, 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