[Senate Hearing 117-214]
[From the U.S. Government Publishing Office]


                                                    S. Hrg. 117-214

                  21ST CENTURY ECONOMY: PROTECTING THE
                 FINANCIAL SYSTEM FROM RISKS ASSOCIATED 
                 WITH CLIMATE CHANGE

=======================================================================

                                 HEARING

                               BEFORE THE

                              COMMITTEE ON
                   BANKING,HOUSING,AND URBAN AFFAIRS
                          UNITED STATES SENATE

                    ONE HUNDRED SEVENTEENTH CONGRESS

                             FIRST SESSION

                                   ON

         EXAMINING THE RISK CLIMATE CHANGE POSES TO OUR ECONOMY

                               ----------                              

                             MARCH 18, 2021

                               ----------                              

  Printed for the use of the Committee on Banking, Housing, and Urban 
                                Affairs
                                
[GRAPHIC NOT AVAILABLE IN TIFF FORMAT]

                               __________

                    U.S. GOVERNMENT PUBLISHING OFFICE                    
47-082 PDF                 WASHINGTON : 2022                     
          
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            COMMITTEE ON BANKING, HOUSING, AND URBAN AFFAIRS

                     SHERROD BROWN, Ohio, Chairman

JACK REED, Rhode Island              PATRICK J. TOOMEY, Pennsylvania
ROBERT MENENDEZ, New Jersey          RICHARD C. SHELBY, Alabama
JON TESTER, Montana                  MIKE CRAPO, Idaho
MARK R. WARNER, Virginia             TIM SCOTT, South Carolina
ELIZABETH WARREN, Massachusetts      MIKE ROUNDS, South Dakota
CHRIS VAN HOLLEN, Maryland           THOM TILLIS, North Carolina
CATHERINE CORTEZ MASTO, Nevada       JOHN KENNEDY, Louisiana
TINA SMITH, Minnesota                BILL HAGERTY, Tennessee
KYRSTEN SINEMA, Arizona              CYNTHIA LUMMIS, Wyoming
JON OSSOFF, Georgia                  JERRY MORAN, Kansas
RAPHAEL WARNOCK, Georgia             KEVIN CRAMER, North Dakota
                                     STEVE DAINES, Montana

                     Laura Swanson, Staff Director

                 Brad Grantz, Republican Staff Director

                       Elisha Tuku, Chief Counsel

                         John Richards, Counsel

                 Dan Sullivan, Republican Chief Counsel

                  Alexander LePore, Republican Detail

                      Cameron Ricker, Chief Clerk

                      Shelvin Simmons, IT Director

                    Charles J. Moffat, Hearing Clerk

                                  (ii)


                            C O N T E N T S

                              ----------                              

                        THURSDAY, MARCH 18, 2021

                                                                   Page

Opening statement of Chairman Brown..............................     1
        Prepared statement.......................................    43

Opening statements, comments, or prepared statements of:
    Senator Toomey...............................................     4

                               WITNESSES

Gregory Gelzinis, Associate Director, Economic Policy, Center for 
  American Progress..............................................     7
    Prepared statement...........................................    44
    Responses to written questions of:
        Senator Cortez Masto.....................................   102
Nathaniel Keohane, Senior Vice President, Climate, Environmental 
  Defense Fund...................................................     9
    Prepared statement...........................................    68
    Responses to written questions of:
        Senator Cortez Masto.....................................   104
Marilyn Waite, Climate And Clean Energy Finance Program Officer, 
  The William and Flora Hewlett Foundation.......................    11
    Prepared statement...........................................    78
John H. Cochrane, Senior Fellow, Hoover Institution, Stanford 
  University.....................................................    12
    Prepared statement...........................................    92
Benjamin Zycher, Resident Scholar, American Enterprise Institute.    14
    Prepared statement...........................................    93

              Additional Material Supplied for the Record

Managing Climate Risk in the U.S. Financial System...............   110
GAO Report: Public Companies--Disclosure of Environmental, 
  Social, and Governance Factors and Options To Enhance Them.....   284

                                 (iii)

 
   21ST CENTURY ECONOMY: PROTECTING THE FINANCIAL SYSTEM FROM RISKS 
                     ASSOCIATED WITH CLIMATE CHANGE

                              ----------                              


                        THURSDAY, MARCH 18, 2021

                                       U.S. Senate,
          Committee on Banking, Housing, and Urban Affairs,
                                                    Washington, DC.
    The Committee met at 10 a.m., via Webex, Hon. Sherrod 
Brown, Chairman of the Committee, presiding.

          OPENING STATEMENT OF CHAIRMAN SHERROD BROWN

    Chairman Brown. The hearing of the Banking, Housing, and 
Urban Affairs Committee will come to order.
    This hearing is in the virtual format. For those joining 
remotely, a few reminders.
    Once you start speaking, there will be a slight delay 
before you are displayed on the screen. To minimize background 
noise, please click the mute button until it is your turn to 
speak or to ask questions.
    You should all have one box on your screens labeled 
``Clock'' that will show you how much time is remaining. For 
all Senators, the 5-minute clock still applies for your 
questions. At 30 seconds remaining, you will hear a bell ring 
to remind you your time has almost expired. It will ring again 
when your time has expired.
    If there is a technology issue, we will move to the next 
Senator until it is resolved. To simplify the speaking order, 
Senator Toomey and I have agreed to go by seniority for this 
hearing.
    Today the Banking and Housing Committee is holding its 
first-ever hearing on the risk climate change poses to our 
economy.
    It makes it the first time our Committee will consider all 
the economic opportunities that exist by addressing climate 
change.
    More than ever, people in Ohio and Pennsylvania and around 
the country are experiencing how climate change affects their 
lives--from devastating hurricanes to raging wildfires, from 
harmful algal blooms in my beloved Lake Erie, to landslides in 
Cincinnati, to erratic farming seasons across the Midwest.
    People are not stupid. They see what is happening; they 
know it threatens not only their air and their water, but it 
threatens their homes and their livelihoods.
    They know also that there are all sorts of opportunities in 
communities in every State that come with taking climate change 
seriously.
    They see the wind turbines across the Great Plains made 
with steel made in Pennsylvania or Ohio or Illinois. They see 
people installing solar panels made in Toledo at one of the 
biggest solar energy manufacturers in the country.
    We cannot have a 21st century economy built on a 19th 
century model. That does not make environmental sense.
    It also does not make economic sense.
    If we want an economy that creates jobs and improves 
infrastructure in all our communities and allows our businesses 
and our workers to compete around the world, then instead of 
running from these opportunities, we have to seize them.
    I want to be clear: It is not the role of this committee to 
vilify--or for that matter, to prop up--any specific technology 
or any source of energy. The work of coal miners in eastern 
Ohio, in Belmont County, has every bit as much dignity as the 
work of a battery manufacturer in Fremont, Ohio.
    We show those workers no respect if we do not plan now for 
how we are going to protect their communities from flooding and 
drought and economic upheaval, and how we are going to protect 
their retirement and their children's college savings from 
risky investments.
    On this Committee, we are charged with looking at anything 
that could hurt the stability of our economy.
    This is a set of issues my Democratic colleagues have 
talked about for a long time.
    And a lot of what we will talk about today got a jump start 
last year when now-Acting CFTC Chair Rostin Behnam created his 
Climate-Related Market Risk Subcommittee.
    The Subcommittee put out an important report, ``Managing 
Climate Risk in the U.S. Financial System.''
    Just yesterday he announced he is establishing a Climate 
Risk Unit in CFTC to focus on the role of derivatives in 
understanding, pricing, and addressing climate-related risk.
    I would like to ask unanimous consent to enter the CFTC 
subcommittee report, ``Managing Climate Risk in the U.S. 
Financial System'', into the record for this hearing. Without 
objection, it is entered.
    Being on the lookout for risk is our job here. We cannot 
always predict what it might be. It could be the business 
decisions of a few bad actors in a particular industry. Or we 
might be forced to act because of events beyond our borders.
    In this case, though, we can predict something that is 
going to hurt the economy. We know--underscore ``know''--that 
climate change threatens the country's financial stability.
    And the financial sector and the Government agencies that 
oversee it are going to have to reckon with the consequences of 
decades of risky investments in industries that fuel natural 
disasters and threaten people's paychecks and threaten their 
retirement security.
    For years, the biggest corporations have fought Government 
action on climate change because CEOs could make a lot of money 
in the short term by endangering our planet in the long term. 
And then those corporations and these CEOs expect workers and 
their families to foot these very expensive bills.
    We cannot protect the economy--and the people who make it 
work--if we do not start by identifying the risks.
    We know far too little about how much climate-related risk 
is sitting on the books of banks and insurance companies.
    It is not a surprise that Wall Street is trying to hide 
just how heavily they have invested in corporate polluters. 
This lack of transparency about the largest U.S. banks' 
significant investments in long-term fossil fuel projects here 
and abroad hides potential financial risks.
    These are risks that workers and families investing their 
pensions and 401(k)s will likely pay the price for.
    We need to know where Wall Street is investing people's 
hard-earned savings. And if it is invested in shrinking 
industries that threaten their jobs and their communities, we 
need to know about it.
    That means looking at stronger transparency rules. It means 
looking at whether the tools that financial watchdogs already 
have can help us shine a light on these risks.
    While some large banks and other companies have voluntarily 
disclosed some of their investments, not enough of them have. 
They are not moving fast enough.
    We needed this years ago.
    Look around. Climate-related disasters are already here, 
already grinding some local economies to a halt, already 
forcing some out of work, already destroying some communities.
    The second polar vortex in a decade to cripple Texas is not 
far behind us. We are already approaching what some are 
predicting will be an above-average hurricane. Those are 
economic risks.
    Persistent drought leaves the Mountain West dealing with 
wildfires that rack up multi-billion-dollar economic losses 
year after year, in fire seasons that are so constant they have 
ceased to be seasons. That is an economic risk.
    Farmers in the Plains States lost an entire planting season 
because of wet fields or flooding that once would have been 
shocking, but now is all too common. That is also an economic 
risk.
    A 3-day downpour flooded 100,000 homes in Houston, forced 
hundreds of thousands of people out of their homes, ground 
commerce to a standstill at one of the three busiest ports in 
the country. With effects like that, it is hard not to think 
that the only way you could fail to see an economic risk, is if 
you are being paid not to see one.
    It is also not enough to just think about the climate risks 
to companies' balance sheets or stock prices. The financial 
industry and our Government have to take into account the risks 
to people's livelihoods, the communities they live in, the food 
they eat, the investments they have made for their retirement.
    And as we look for opportunities, we need to make sure that 
American industry--steel and aluminum, paper and autos, and 
beyond--can access the capital they need to reduce or eliminate 
emissions.
    And when we increase transparency across the financial 
sector and take into account the clear economic costs of 
climate change, then lenders and industry and workers will be 
rewarded by making those capital investments.
    Today we will hear from five witnesses who will share their 
insights and expertise on these risks and the opportunities we 
have to protect and rebuild our economy. I hope my colleagues, 
all of us, will keep an open mind about all of this.
    Every day we delay is another missed opportunity to invest 
in new technologies, in new industries, to make our businesses 
more competitive, to create jobs in communities that have so 
often been left behind. The Ranking Member and I have many 
places in our States that feel that way.
    If we do not tell people the truth and take this seriously, 
we know who pays the price. It is never CEOs. It is never the 
corporate boards. It is never people that work at think tanks. 
It is never Senators who pay the price.
    It is going to be the ranchers in North Dakota and South 
Dakota, the line cook in New Orleans, the kindergartner with 
asthma in Las Vegas, the steel worker in Cleveland, the clerk 
in New Hampshire.
    It is their jobs, their savings, and their futures on the 
line. It is our job to be on their side.
    Senator Toomey is recognized for 5 minutes or whatever you 
need.

         OPENING STATEMENT OF SENATOR PATRICK J. TOOMEY

    Senator Toomey. Thank you, Mr. Chairman.
    The title of today's hearing is ``21st Century Economy: 
Protecting the Financial System from Risks Associated with 
Climate Change,'' which begs the question: Who is supposed to 
protect the financial system from these risks, and how?
    In the view of at least some of my Democratic colleagues, 
the answers seem to be the Fed, the SEC, and other----
    Chairman Brown. Your volume is off. There we go.
    Senator Toomey. Can you hear me now? Can you hear me, Mr. 
Chairman? Can you hear me now? I am not on mute, according to 
my screen.
    Senator Smith. I can hear you, Senator Toomey. This is 
Senator Smith.
    Senator Toomey. OK. Thank you, Senator Smith. Cameron, can 
you hear me?
    Mr. Ricker. Yes, sir, I can hear you.
    Senator Toomey. OK.
    Chairman Brown. Everybody else hears you but me. I do not 
know quite what is wrong. Sorry about that.
    Senator Toomey. Why don't I resume?
    Chairman Brown. Go ahead.
    Senator Toomey. OK, I will resume. And what I want to do is 
offer a different perspective.
    Just as we would not task the EPA with auditing corporate 
books even of energy companies, financial regulation and 
supervision is not meant for advancing environmental policy. As 
Fed Chairman Powell himself has said, ``Society's broad 
response to climate change is for others to decide, in 
particular elected leaders. If Congress believes current 
environmental policies do not adequately address climate risk, 
then changes should be enacted through the legislative process, 
not through financial regulation.''
    Of course, this should be the responsibility of Congress. 
It is Congress that is accountable to the American people and 
would take responsibility for the costly tradeoffs if, for 
instance, we decided to rely more on expensive renewable energy 
rather than less expensive conventional energy.
    Regarding the Fed, the climate policy is clearly beyond the 
scope of its mission and authorities. The Fed was created to be 
independent and free from political influence. As one of 
today's witnesses, John Cochrane, has observed, ``A central 
bank in a democracy is not an all-purpose do-good agency to 
subsidize what it decides to be worthy, defund what it 
dislikes, and force banks and companies to do the same.''
    The Fed's recent actions on climate, however, suggest that 
this is the direction that some at the Fed would like to 
pursue. For example, the Fed's newly created committee that is 
focused exclusively on climate risk raises a number of 
questions. Although it was announced nearly 2 months ago, we 
still do not have any details on its objective or how it 
intends to achieve them. Similarly, Fed Governor Lael Brainard 
has suggested the Fed may require banks to engage in ``climate 
scenario analysis,'' but she has not provided any specificity 
on the purpose or rationale or process for such an exercise. 
And this is in spite of the fact that banks already evaluate 
their risks and respond accordingly. By straying from its core 
mission and authorities in support of vague and ill-defined 
climate goals, the Fed's actions threaten to undermine its 
credibility and to betray its independence.
    Climate policy is also beyond the scope of the Fed's 
expertise. We know there are significant shortcomings and gaps 
in climate models and data. The Fed has acknowledged that 
historical climate data is insufficient to make accurate 
predictions of future climate scenarios. And climate 
researchers themselves have warned that their models are built 
for 100-year simulations, not projections of the immediate 
years or even decades ahead.
    Given the uncertainty within the climate community itself, 
why should we believe that the Fed has a greater understanding 
of climate risks than regulated institutions? The answer is we 
should not.
    One recent paper by a group of climate researchers found 
that current climate models cannot provide financially 
meaningful information. The Fed should not become a climate 
soothsayer any more than they should start regulating based on 
the risk of domestic instability, widespread famine, or other 
black swan events. As one of today's witnesses, Ben Zycher, 
will explain in more detail, the Fed is not in a position to 
navigate the enormous uncertainties and complexities underlying 
climate models. Financial regulators just have no experience or 
expertise in environmental policy, and any attempt to impose 
new requirements will only result in the Government picking 
winners and losers.
    The Fed should not follow the example of some other 
regulators engaged in mission creep, nor should the SEC. I have 
warned that many on the left want the SEC to use its regulatory 
powers to advance a progressive social agenda, including on 
climate change. Now under the SEC's Acting Chair, the agency is 
beginning to do exactly that.
    For example, earlier this month, the SEC announced the 
creation of a Climate and ESG Task Force to scrutinize issuers' 
disclosure of climate risk. And on Monday, the Acting SEC Chair 
proposed a chilling and authoritarian idea. She argued the SEC 
should force companies to disclose any type of political 
advocacy spending because firms may, and I quote, ``state that 
they support climate-friendly initiatives but have donated 
substantial sums to candidates with climate voting records 
inconsistent with such assertions.''
    Well, inconsistent according to whom? I mean, what this 
really means is that these green friendly companies may support 
some Republicans, and that is unacceptable. These actions 
represent a clear abuse of power and a politicization of the 
SEC's disclosure standard. The concept of materiality is the 
cornerstone of the disclosure- based regime under Federal 
securities laws, and what matters is whether an issue is 
financially material to a reasonable investor.
    The real objective here seems to be to punish politically 
disfavored industries. By straying from beyond their mandates 
into the climate arena, financial regulators will pressure 
banks not to serve politically disfavored industries such as 
fossil fuel companies. But who is next? Gun manufacturers? 
Conservative media? Religious-minded businesses like Hobby 
Lobby? This is a wholly inappropriate use of financial 
regulation in an attempt to substitute political favoritism for 
private business decisions.
    Radical policies to force banks to cutoff capital to these 
companies would not have a meaningful impact on the climate, as 
Dr. Zycher will testify, but will only raise energy prices for 
consumers.
    So I began my statement by asking, Who is supposed to 
protect the financial system from risks associated with climate 
change and how? Or you could simply ask, Exactly what risks? 
The major threat to energy-related assets is not financial risk 
caused by weather-related events. It is the risk that 
unelected, unaccountable, woke regulator will misuse the levers 
of power in ways never imagined to remake society according to 
their politics. That result, political favoritism caused by 
regulatory abuse, that is what we really need to protect the 
financial system, business, and workers from.
    Chairman Brown. Thank you, Senator Toomey, and I apologize 
for the beginning. I guess all of you could hear and for some 
reason we could not. I apologize for interrupting like that. So 
thank you for your words.
    I will introduce today's witnesses. We will hear from five 
witnesses.
    Gregory Gelzinis is the associated director for economic 
policy at the Center for American Progress. At CAP, Mr. 
Gelzinis focuses primarily on financial institutions, financial 
markets, and consumer finance policy. His experience includes 
stints at Swiss Re, the Federal Home Loan Bank of Atlanta, and 
on Capitol Hill.
    Dr. Nat Keohane is the senior vice president, climate, the 
Environmental Defense Fund. He is a Ph.D. economist, leads 
EDF's climate program. He is an adjunct professor at the New 
York University School of Law where he teaches a seminar on 
climate change policy. During the Obama administration, Dr. 
Keohane was appointed to be a Special Assistant to the 
President for Energy and Environment on the National Economic 
Council and Domestic Policy Council.
    Ms. Marilyn Waite is the climate and clean energy finance 
program officer at the William and Flora Hewlett Foundation. 
She manages the foundations grantmaking and other activities in 
the foundation's climate and clean energy finance portfolio. 
Prior to joining Hewlett, she worked on clean energy venture 
investment and economic development on four continents.
    Dr. John Cochrane is the Rose-Marie and Jack Anderson 
Senior Fellow at the Hoover Institution at Stanford University. 
Prior to Stanford, Dr. Cochrane taught first in the Economics 
Department, later in the Booth School of Business at the 
University of Chicago, where he was the AQR Capital Management 
Distinguished Service Professor of Finance.
    And, last, Dr. Benjamin Zycher is a resident scholar at the 
American Enterprise Institute. Dr. Zycher researches and writes 
on energy and environmental policy for AEI. Prior to joining 
them, Dr. Zycher ran his own public policy research firm, 
served in the Office of Economic Analysis, Bureau of 
Intelligence and Research at the U.S. Department of State. He 
taught economics at UCLA and at Cal State, Channel Islands. He 
has been a senior economist at RAND and the Jet Propulsion Lab, 
was a senior staff economist of the Council of Economic 
Advisers for President Reagan.
    We are fortunate to have such an esteemed panel of experts 
to discuss a topic that I believe Banking and Housing is 
frankly overdue tackling, namely, potential impacts on our 
economy from climate change and climate- related risks to the 
financial system. I welcome all five of our witnesses. I thank 
you all for agreeing to appear before our Committee.
    Mr. Gelzinis, I welcome you to give your opening remarks, 
and we will follow with other witnesses in the order I have 
introduced you this morning. So, Mr. Gelzinis, if you would 
begin. Thank you.

  STATEMENT OF GREGORY GELZINIS, ASSOCIATE DIRECTOR, ECONOMIC 
              POLICY, CENTER FOR AMERICAN PROGRESS

    Mr. Gelzinis. Thank you. Chairman Brown, Ranking Member 
Toomey, and Members of the Committee, thank you for the 
opportunity to testify before the Committee on this critical 
issue. My name is Gregory Gelzinis. I am an associate director 
for economic policy at the Center for American Progress, where 
I research, and advocate for, policies that would create a 
safer, more stable, and less predatory financial system--one 
that is well positioned to support long-term economic growth.
    The coronavirus pandemic has proven to be a terrifying 
reminder that our collective livelihoods can be upended by 
catastrophic exogenous shocks, seemingly at a moment's notice. 
It is incumbent on policymakers to use this experience as a 
catalyst toward addressing the impending exogenous shock that 
will likely disrupt our lives on a much greater scale: climate 
change.
    The climate crisis has profound implications for life and 
health, as it challenges our very ability to sustain a 
habitable planet. Climate change is also going to have a 
fundamental impact on every sector of our economy, including 
the sector we are here to discuss today: the financial sector.
    The increase in frequency and severity of extreme weather 
events and long-term environmental shifts threatens an array of 
real assets and financial assets. From commercial and 
residential real estate exposures along the coast to 
agricultural lending in the Midwest, climate change could 
severely impair the value of physical collateral, disrupt 
supply chains, limit economic activity, increase financial 
uncertainty, and strain profitability. These effects would 
reduce real estate and commodity values, lower corporate equity 
prices, and limit the ability of businesses and households to 
repay debt.
    In addition, the financial system is exposed to transition-
related risks. If policymakers take the legal and regulatory 
actions necessary to meet emissions and temperature targets, 
financial institutions whose balance sheets do not align with 
the transition could face significant losses. Financial 
instruments tied to carbon- intensive sectors could face a 
severe repricing as policies restrict and raise the costs of 
emissions. Technological advancements and shifts in investor 
sentiment could also trigger such losses in advance of any 
legal or regulatory actions.
    Under certain scenarios, financial institutions could 
adjust to these transition effects abruptly, bursting the 
carbon bubble and creating what former Bank of England Governor 
Mark Carney has coined a ``climate Minsky moment.''
    Climate change does not only present risks to individual 
financial institutions. It also poses a systemic threat due to 
the potential magnitude of the physical and transition-related 
risks, the wide array of financial institutions and markets 
exposed to these risks, and the speed with which these possibly 
correlated risks could materialize. These risks are not 
theoretical. In just the past 2 years, we have seen arguably 
first climate bankruptcy in PG&E and witnessed energy companies 
like BP and Total, write down the value of stranded assets, as 
energy price assumptions are recalibrated.
    The financial sector is finally starting to adjust to these 
risks, and recent net-zero commitments from the largest Wall 
Street banks are a welcome development, although such 
commitments have been light on details and lack near-term plans 
to meet those long-term goals. But it is critical for 
regulators to step in and account for these risks in the 
supervision and regulation of the financial system. We cannot 
let Wall Street write the rules and rely upon the disproven 
strategy of self-regulation, especially as these firms continue 
to finance the very drivers of the climate crisis that put 
their own balance sheets, as well as those of responsible 
firms, at risk.
    Financial regulators have broad responsibilities under 
existing law to mitigate these climate-related risks. Markets 
regulators have a responsibility to protect investors, to 
promote transparency, and to foster healthy markets for 
securities and derivatives. Prudential regulators have a 
statutory mandate to ensure the safety and soundness of 
financial institutions and to promote the stability of the 
financial system.
    Climate change clearly falls within these mandates, and a 
failure to mitigate climate-related risks would violate the 
duties Congress bestowed upon the financial regulators. 
Thankfully, over the past few months a bipartisan collection of 
U.S. financial regulators have acknowledged that climate change 
falls within their remit. Even though the U.S. is several years 
behind its international peers, recent actions and 
announcements by the White House, Treasury Department, Fed, 
SEC, CFTC, FHFA, FDIC, and State-level regulators signal that 
momentum is building. Like many economic variables, these risks 
will not be easy to model or quantify, given the inherent 
uncertainty climate change entails. But the potential magnitude 
of the risk demands regulators employ a precautionary principle 
and safeguard the financial system from the worst outcomes.
    Integrating climate change into corporate and financial 
disclosure requirements, fiduciary obligations, stress testing, 
supervision, capital requirements, and systemic risk oversight 
would bolster the resilience of the financial system and 
position it to serve as a source of strength to the economy 
during the low-carbon transition. If regulators fail to act 
with sufficient speed or refuse to use their full panoply of 
tools, it is imperative for Congress to insist that they do so. 
The stakes are simply too high.
    Thank you, and I look forward to your questions.
    Chairman Brown. Thank you very much, Mr. Gelzinis.
    Dr. Keohane.

STATEMENT OF NATHANIEL KEOHANE, SENIOR VICE PRESIDENT, CLIMATE, 
                   ENVIRONMENTAL DEFENSE FUND

    Mr. Keohane. Thank you. Chairman Brown, Ranking Member 
Toomey, and honorable Members of the Committee, thank you for 
inviting me to testify with such a great group.
    My name is Nat Keohane, and I am the senior vice president 
for climate at Environmental Defense Fund, a global, U.S.-
based, nonprofit environmental organization with over 2 million 
members and activists. This is a timely and urgent hearing as 
the impacts of climate change grow more visible every year.
    I would like to make three main points.
    First, climate change poses significant risks to the U.S. 
economy and financial system. I was a member of the Climate-
related Market Risk Subcommittee of the Commodity Futures 
Trading Commission that Chairman Brown mentioned and the co-
author of that report, which was unanimously approved by the 
subcommittee's 34 members drawn from a range of industries and 
civil society. The report conveys a stark message to financial 
institutions, regulators, and policymakers: Climate change 
poses serious risks that, if ignored, will undermine the 
financial system's ability to support the American economy.
    As the report shows, climate risk extends throughout the 
economy, covering sectors including agriculture, airlines, 
automobile manufacturers, hospitality, power generation, and a 
wide range of industrial sectors like concrete and steel. The 
report highlights some specific examples of financial 
institutions and assets that are particularly vulnerable to 
climate risk. Here are a few.
    Regional and community banks, whose loan books are 
typically dominated by commercial real estate loans in a given 
area. As a result, local financial institutions in areas of 
climate risk, coastal areas or areas vulnerable to hurricanes, 
are particularly vulnerable to climate risk and to the 
financial risk it conveys.
    Second, agricultural banks, which also face correlated risk 
because of their concentrated loans in particular geographic 
areas and in the agricultural businesses, a credit-stressed 
agricultural lending system, which we have already seen signs 
of in the Midwest in recent years, would decrease farmers' 
access to affordable credit and make it harder to recover from 
climate shocks.
    Municipal bonds are a third example. An analysis from 
BlackRock Institute demonstrated that municipalities threatened 
by climate change could face significant losses of GDP, 
impairing their ability to service their obligations, and 
raising financial risk to bond holders.
    In other words, this is not just about big banks on Wall 
Street. This is about everyday transactions on Main Street: 
commercial real estate loans, farm credit, and small business 
loans that underpin the U.S. economy and that depend on a 
stable financial system.
    How likely are these climate risks? The scary answer is we 
do not know because we are not tracking them and getting the 
information we need. Members of the financial community who 
ignore climate change, whether they are banks, investors, or 
regulators, do so at their peril.
    So this leads to my second point, which is that financial 
regulators have a clear responsibility to address climate risk, 
particularly with respect to mandatory climate disclosure. It 
is important to note that the duties and authorities of 
regulators remain the same as they have been. What is new is 
the magnitude and materiality of climate risk.
    The most important recommendation for regulators is that 
the SEC should strengthen mandatory climate risk disclosure in 
order to drive comparable, specific, and decision-useful 
information from regulated entities rather than the boilerplate 
climate reporting that is all too common. Better disclosure of 
climate risk would benefit investors, companies, and the 
American public and improve the functioning of markets.
    My third and last point is that there is significant demand 
and opportunity to channel private capital into low- carbon and 
climate-friendly investment opportunities. Over the past 5 
years, we have seen private demand increase dramatically for 
this kind of lending. The Climate Action 100+ Initiative, 
designed to support transition to net-zero business strategies, 
now has nearly 550 investors and $52 trillion in assets under 
member management.
    In this area of opportunity, the single most important 
thing that policymakers could do in order to ensure that 
private capital flows more efficiently to low-carbon economies 
is to implement a fair and effective price on carbon across the 
economy. This is a core recommendation as well of the CFTC 
report that I mentioned at the beginning.
    In conclusion, climate change poses significant risks to 
the U.S. financial system, but well-designed policies, 
particularly including strengthening mandatory climate risk 
disclosure rules and implementing a price on carbon, could help 
to manage and mitigate those risks.
    Thank you for your attention.
    Chairman Brown. Thank you, Dr. Keohane.
    Ms. Waite, you are recognized for 5 minutes. Thank you for 
joining us.

 STATEMENT OF MARILYN WAITE, CLIMATE AND CLEAN ENERGY FINANCE 
   PROGRAM OFFICER, THE WILLIAM AND FLORA HEWLETT FOUNDATION

    Ms. Waite. Chairman Brown, Ranking Member Toomey, and 
Members of the Committee, thank you for inviting me to testify 
today.
    I am a program officer for climate and clean energy finance 
at the William and Flora Hewlett Foundation where my work 
involves setting and implementing securities to mobilize 
capital for climate change solutions. I focus primarily on 
venture capital, asset management, and bank lending, including 
the market rules needed to decarbonize the financial system. 
Prior to the foundation, I worked in nuclear and renewable 
energy and venture capital for clean transportation.
    In 2020, the United States experienced almost two dozen 
separate climate-related disasters, exacerbating the economic 
toll of COVID-19 and costing $95 billion. As climate change 
continues, we will see a number of sectors hurt from aviation--
think of crippling heat grounding planes in Arizona--to 
agriculture, with heavy rain and snow overwhelming the Western 
farms.
    As both climate-related physical and transition risks 
indicate, the financial system and the real economy will be 
devastated as the planet continues to warm, with real losses 
already manifesting in some sectors and assets classes. The 
challenge goes far beyond just protecting the financial system 
from climate risk. In fact, finance is an essential part of 
solving climate change and can do so while creating jobs and 
innovation. The U.S. must bring our annual 6 gigatons of carbon 
emissions down to zero, which requires roughly $250 billion of 
additional investment annually.
    Taken together, the following practical policy actions 
endorsed by key finance experts can unlock the capital needed. 
After all, we have $15 trillion sitting in our everyday account 
as deposits. Mobilizing less than 2 percent of that will allow 
us to achieve a net-zero goal.
    First, we must get our measurement house in order for 
transparency and accountability. Policymakers, including the 
SEC and OCC, should require financial institutions to measure 
and disclose the carbon emissions of their loans and 
investments. This should be done on an annual basis with very 
clear reduction targets. Banks and asset managers representing 
over $25 trillion, including credit unions in Montana and 
trillion-dollar banks in North Carolina, are already doing so. 
Yet to protect the entire financial system and real economy, 
Government must step in and mandate this accounting for all.
    Second, we must climate-proof the Nation's balance sheet. 
The Federal Reserve must use the absolute emissions data 
provided by banks to increase the risk rates for loans in 
climate change-driving assets.
    Third, we have to enable community-focused lenders to scale 
climate-friendly loans. Communities of color bear the brunt of 
environmental pollution and are likely to be disproportionate 
impacted by unabated climate change. The good news is that 
there are over 100 MDIs, 1,000 CDFIs, 5,000 credit unions, and 
5,000 deposit-taking banks that stand ready to support 
communities in wealth-building decarbonization. Treasury should 
provide secondary capital into community-focused lenders to 
support long-term climate resiliency.
    Fourth, we can deploy trillions without public spending 
through mandates mirrored after the Community Reinvestment Act. 
Not only can the existing CRA be strengthened to explicitly 
provide credit for climate-friendly loans, Congress can instate 
a new mandate that incentivizes banks to invest in climate-
friendly infrastructure.
    Fifth, we must enable consumer finance for climate action. 
Just as mobile number portability in telecommunications and the 
automated customer account transfer service in broker-dealers 
lowered the barriers to customer choice, so too can new 
policies by the CFPB lower the cost of closing and switching 
bank accounts.
    Finally, policymakers at all levels of Government, 
including the SEC, FINRA, and the Department of Labor, should 
modernize fiduciary duty definitions to align with climate risk 
and impact. DOL should issue rules to require ERISA plan 
managers to adopt and implement sustainable climate-friendly 
investment policies.
    In summary, the market rules that enable a climate-safe 
economy should be as robust, pervasive, and serious as the 
climate crisis itself. Financial regulation and congressional 
mandates should ensure that the recovery is one that brings 
prosperity to all.
    Thank you.
    Chairman Brown. Thank you, Ms. Waite.
    Dr. Cochrane, you are recognized for 5 minutes. Thank you 
for joining us.

     STATEMENT OF JOHN H. COCHRANE, SENIOR FELLOW, HOOVER 
                INSTITUTION, STANFORD UNIVERSITY

    Mr. Cochrane. Thank you. Chairman Brown, Ranking Member 
Toomey, and Members of the Committee, thank you very much for 
the opportunity to testify today.
    Climate change is a very important challenge. But climate 
change poses no measurable risk to the financial system. 
``Risk'' means unforeseen events. We know exactly where the 
climate is going over the horizon that financial regulation can 
contemplate. Weather is risky, but even the biggest floods, 
hurricanes, and heat waves have essentially no impact on our 
financial system, and they are well modeled.
    Moreover, the financial system is only at risk when 
financial institutions as a whole lose so much, and so 
suddenly, that they blow through their capital, and a run on 
short-term debt erupts. That climate may cause a sudden, 
unexpected, and enormous economic effect which could endanger 
the financial system is a fantasy.
    Now, sure, we do not know what will happen in 100 years. 
But banks did not fail in 2008 because they bet on radios, not 
TV, in the 1920s. Financial regulation does not try to look 
past 5 or 10 years or so. Sure, a switch to renewables might 
lower oil company profits. Oil stockholders might lose money. 
But risk to the financial system cannot mean that nobody ever 
loses any money. Tesla could not have been built if people 
could not take risks.
    So why is there a push for regulators to take on fictitious 
climate risks? These proposals aim simply to defund the fossil 
fuel industry before alternatives are available and to steer 
funds to fashionable but unprofitable investments, by 
regulatory subterfuge rather than aboveboard legislation or 
transparent agency rulemaking.
    This goal is not a secret. For example, the NGFS, which the 
Federal Reserve recently joined, states plainly its goal is to 
``mobilize mainstream finance to support the transition toward 
a sustainable economy.'' But financial regulators are not 
allowed to mobilize the financial system to projects they 
choose and to defund projects they disfavor. So regulators must 
pretend that they are dispassionately finding risks to the 
financial system, and oh, we just happen to stumble on climate 
here.
    There are plenty of genuine severe risks to the financial 
system. Imagine a new pandemic, one that kills 10 percent of 
people and lasts for years without a vaccine. Suppose China 
invades Taiwan or a nuclear bomb goes off. Suppose there is a 
sovereign debt crisis. What happens if Treasury cannot roll 
over its big debts and banks no longer take Treasury 
collateral? Suppose a massive cyber attack wipes out the 
accounts at a major bank and everybody rushes for cash 
everywhere. These would indeed be genuine financial system 
catastrophes. Yet of all of these large, obvious, and plausible 
risks, our financial regulators want to focus on just one, a 
fictitious climate risk. Why? Well, obviously, the end 
justifies the means.
    Climate is really important. Climate is too important to 
let financial regulators play with it. Climate needs clear-
headed, science-based, steady, transparent policy, with 
explicit cost-benefit analysis. Underhandedly funding and 
defunding financial regulators' enthusiasms will produce 
counterproductive feel-good policies.
    True climate answers might include nuclear power, 
geoengineering, carbon capture, hydrogen fuel cells, 
genetically engineered foods, zoning reform, a carbon tax, as 
Dr. Keohane suggested, and other approaches, which financial 
regulators will never envision. If we had done this 10 years 
ago, we would not have hydraulic fracking and natural gas, 
which means the U.S. is leading the world in carbon reductions 
and without which Russia, Iran, and Saudi Arabia would be 
rolling in the money and America would be in much worse 
economic shape.
    Financial regulation is too important to be eviscerated on 
the altar of defunding fossil fuels. Financial regulation needs 
to get back to making sure that financial institutions have 
capital to withstand all sorts of shocks which nobody can 
foresee. It is hard work and it is boring work. You do not get 
invited to Davos. Industry hates being told to get more 
capital. But that is their job, and there is plenty to do.
    The financial system is in peril. Last year was an abject 
failure. Despite 12 years of intensive regulation and stress 
tests and centuries of experience, financial regulators never 
thought a pandemic might come. We made it through the last year 
by one more massive bailout, not regulatory prescience, and now 
they want to soothsay the climate?
    Do not let the EPA regulate banks. Do not let our financial 
regulators dream up climate policy. You will get bad climate 
policy and a more fragile and sclerotic financial system if you 
do.
    Chairman Brown. Thank you, Dr. Cochrane.
    Dr. Zycher is recognized for 5 minutes.

   STATEMENT OF BENJAMIN ZYCHER, RESIDENT SCHOLAR, AMERICAN 
                      ENTERPRISE INSTITUTE

    Mr. Zycher. Thank you, Chairman Brown and Ranking Member 
Toomey.
    Neither Government agencies nor financial institutions are 
in a position to evaluate climate phenomena with respect to 
which the scientific uncertainties are vastly greater than 
commonly asserted. The range of alternative assumptions about 
central parameters is too great to yield clear implications for 
the climate ``risks'' attendant upon the allocation of 
financial capital among economic sectors. Those central 
parameters include choices among climate models, the assumed 
sensitivity of the climate system, the assumed future increase 
in greenhouse gas concentrations, and many others.
    If the Federal Reserve and the financial institutions opt 
to use similar sets of analytic assumptions, a very real danger 
would arise of more or less homogeneous predictions 
inconsistent with the evidence on climate phenomena. If instead 
opt to us differing sets of assumptions, the ensuing 
predictions about future climate phenomena--that is, risks-- 
would vary substantially, yielding very large uncertainties in 
terms of attendant implications.
    Financial institutions would have powerful incentives to 
undertake climate analysis driven not by the actual evidence 
and the peer-reviewed literature. Instead, they will be driven 
to undertake such analysis under assumptions and methodologies 
distorted by regulatory directives, political pressures, and 
litigation threats.
    The aggregate benefits--that is, the positive risks--of 
increasing greenhouse gas concentrations, as reported by NOAA 
and in the peer-reviewed literature, almost certainly will be 
excluded from the analyses of climate risks. Such analyses will 
exclude also the risks of climate themselves, prominent among 
which are the large and adverse implications of artificial 
increases in energy costs. Such policy risks are likely to be 
greater when implemented by bureaucracies insulated from 
democratic accountability.
    In any event, the major integrated climate and economy 
model used by the U.S. Government suggests that the future 
aggregate economic risks of anthropogenic climate change are 
much smaller than many assert. Anthropogenic climate change is 
real, increasing atmospheric concentrations of greenhouse gases 
have yielded effects that are detectable, but they are much 
smaller than commonly asserted, and there is no evidence--
none--in support of the climate crisis argument. We can discuss 
this later if any members of the Committee deem it appropriate 
to do so.
    Moreover, temperature trends are driven by both natural and 
anthropogenic influences that peer-reviewed literature suggests 
the anthropogenic effects are responsible for about one-third 
of the overall temperature increase observed since the end of 
the Little Ice Age. The mainstream climate models have 
predicted the actual temperature trend in recent decades 
correlate, consistently overstating that trend by a factor of 
more than two.
    Application of the EPA climate model predicts that climate 
policies, whether implemented by the U.S. Government alone or 
as an international cooperative policy, would have temperature 
effects by 2100 that would be virtually undetectable. Such 
policies cannot satisfy any plausible benefit-cost test.
    The incorporate of climate ``risks'' into the business 
decisions of financial institutions would weaken the 
materiality standard for disclosures by those institutions. 
``Materiality'' always has meant the disclosure of information 
directly relevant to the financial performance of the bank or 
other institution. When ``risk'' analysis becomes an arbitrary 
function of difficult choices among complex assumptions, the 
traditional materiality standard inexorably will be diluted and 
rendered far less useful for the financial markets, an outcome 
diametrically at odds with the ostensible objectives of those 
advocating the evaluation of climate ``risks.''
    The reality is that a climate risk disclosure requirement 
would be deeply speculative, and the level of detail and the 
scientific sophistication that would be needed to satisfy such 
a requirement are staggering. Such disclosures and supporting 
analysis and documentation would take up many thousands of 
pages, with references to many thousands more, and the premise 
that this disclosure requirement would facilitate improved 
decisionmaking by the financial sector is difficult to take 
seriously.
    A far wiser approach would entail allowing market forces to 
make such risk determinations in a bottom-up fashion, thus 
avoiding an obvious politicization of the allocation of 
capital.
    These proposals represent a blatant effort to distort the 
allocation of capital away from economic sectors disfavored by 
certain political interest groups pursuing ideological agendas. 
This would represent the return of Operation Choke Point.
    Thank you again, Chairman Brown and Ranking Member Toomey. 
I will be pleased to address any questions that members of this 
Committee may have.
    Chairman Brown. Thank you, Dr. Zycher.
    Mr. Gelzinis, I will start with you. What should financial 
regulators do to make sure banks meet their 2030 and 2050 low-
carbon goals? Should regulators have a responsibility to 
protect the banking system and responsible financial 
institutions from banks that fund activity that contributes to 
climate change?
    Mr. Gelzinis. Yes, thank you for the question, Mr. 
Chairman. In terms of meeting 2030 and 2050 targets that banks 
are setting, I think regulators can use stress testing, 
transition risk adjustments to our risk-rated capital 
framework, and risk management standards that include 
actionable transition plans. And just to be clear, these 
policies are not intended to achieve climate goals. They are 
intended to bolster the resilience of banks in the face of the 
inevitable decarbonization of our economy.
    And I am glad you asked the question, Mr. Chairman, about 
banks that are financing, you know, emissions-driven sectors. 
On banks that fund that climate change activity, Dodd-Frank is 
quite clear that regulators should not only focus on the risks 
a financial institution is facing, but also the risks that its 
ongoing activities are creating for other financial firms. So 
those banks funding significant emissions should have to 
internalize the costs they are placing on other banks.
    Chairman Brown. Thank you.
    Dr. Keohane, banks have made a number of commitments to 
supporting a transition to a low-carbon 21st century economy. 
What steps should these banks take to show that this just is 
not a PR campaign and that the banks will take the steps they 
need to take to make good on these promises?
    Mr. Keohane. Thank you, Mr. Chairman. I can identify three 
areas where I think banks can do more, and I will just open by 
saying I think it is--and I mention this in my written 
testimony. I think it is a welcome sign that a number of major 
banks, including Bank of America, Citi, Goldman Sachs, JPMorgan 
Chase, Morgan Stanley, Wells Fargo, they have all made net-zero 
commitments, and I just want to make a point. They have done 
that not because of some regulatory requirement or some 
regulator in Washington or bureaucrat in Washington. They have 
done it because there is enormous demand from their customers 
to do this. And so I just want to make that point because that 
is--when we talk about what banks are doing, we talk about how 
they are responding to the demand of their customers. From our 
point of view, we think there is more that they should do, and 
I think that is reflected because they are hearing that from 
their customers.
    The first point is transparency. We have seen a lot of 
pledges. That is valuable. Now we need to see the plans. We 
need to see how they are going to measure and report their 
financed emissions, how they are going to reduce their own 
emissions, but more importantly, how they see reducing the 
emissions in their portfolios. And, you know, we need to see 
what their plans are for reducing or compensating for remaining 
emissions. So that transparency piece is the first.
    The second is engagement. In particular, we see lots of 
room for engagement. For example, with oil and gas companies, 
during the transition to a low-carbon future, we need to be 
addressing methane emissions from the oil and ga sector. This 
is the easiest and cheapest way to cut warming now. And there 
is a lot that banks can do and companies can do to engage with 
oil and gas companies. This is already happening, and we need 
to see more of it.
    Finally, policy advocacy. One thing I would like to see 
banks do is call for and support mandatory climate risk 
disclosure. They acknowledge that climate risk is material, but 
too many of them or too many companies are still putting 
boilerplate comments together. We would like to see more robust 
disclosure.
    Chairman Brown. Thank you, Dr. Keohane.
    Ms. Waite, you discussed enabling community-focused lenders 
to lead in your testimony as a way low-income and middle-class 
communities and communities of color can take advantage of the 
opportunities that come with addressing climate change. Expand, 
if you would, on what community- focused lenders can do to 
improve the lives of those they serve and mitigate the effects 
of both climate change and the industrial pollution that they 
have endured for so long. What are the opportunities you see 
for both banks and for businesses?
    Ms. Waite. Thank you, Chairman. Community-focused lenders 
are already helping communities mitigate and build wealth 
through energy savings. They are providing affordable loans for 
electric vehicles, healthy and efficient HVAC systems, and 
rooftop solar. In its first 3 years of operation, the Clean 
Energy Federal Credit Union, for example, has recorded zero 
delinquencies and has sown loan participation across the U.S., 
including Tennessee, Wyoming, Pennsylvania, and Montana.
    As a low-income-designated cooperative bank, they are 
already teaching other credit unions how to value this asset 
class. Remember that for some lenders who have a high exposure 
to the dwindling taxi medallion industry, the clean energy 
asset class provides an opportunity for diversification.
    For businesses, which do not have credit scores, community-
focused lenders who know local operations are well positioned 
to provide products and services as they transition their 
assets to low carbon. At the same time, we see the need for 
injection of long-term low-cost capital to enable rapid scaling 
of these lending capacities.
    Chairman Brown. Quickly, a couple of yes-or-no questions to 
Dr. Cochrane and Mr. Gelzinis, if you would answer. Dr. 
Cochrane, regardless of climate change, I understand that you 
believe banks, the largest banks, should have much higher 
capital requirements than they do currently. Is that correct?
    Mr. Cochrane. For all risks, not just climate, yes.
    Chairman Brown. Right. The Federal Reserve weakened the 
supplemental leverage ratio last year, effectively lowering 
capital standards. Do you think the Fed should extend that 
exemption past the end of this month?
    Mr. Cochrane. Yes, I do, because leverage is not capital.
    Chairman Brown. Thank you.
    Senator Toomey is recognized.
    Senator Toomey. Thank you, Mr. Chairman.
    Dr. Cochrane, you correctly noted that the far-reaching 
postcrisis financial regulatory framework that was imposed on 
financial institutions completely failed to consider the 
possibility of a global pandemic disrupting the financial 
system. Do you think the financial regulators would correctly 
anticipate the way that climate change will affect different 
regions of the country in the course of the next 3 or 4 or 5 
years?
    Mr. Cochrane. No.
    Senator Toomey. I do not think so either.
    Mr. Cochrane. I cannot expand on that one.
    [Laughter.]
    Senator Toomey. A yes-no answer is OK. Let me ask you this: 
You also noted that central banks and certainly the Fed has no 
authority to steer credit to areas they like and to defund 
areas that they disfavor. Could you talk a little bit about 
some of the risks if the Fed were to take it upon itself to 
become an allocator of credit even if it did so indirectly?
    Mr. Cochrane. Well, it is going to send things into 
whatever pet projects the Fed decides are fun than into things 
that it does not.
    I should clarify a previous answer. The reason is because 
there is no risk of climate within 4 or 5 years to different 
regions of the country. ``Risk'' means things you do not know 
what is going to happen. We know what the weather is going to 
be like for the next 4 or 5 years.
    Senator Toomey. And with respect to extreme weather events, 
to what extent do financial institutions already consider the 
applicable risks associated with weather? So, for instance, if 
you are a bank and you lend money for the development of 
condominiums on the waterfront in South Florida, do you think 
it occurs to that bank to think that maybe a hurricane will 
come along at some point?
    Mr. Cochrane. Yeah, there is a big confusion here of 
climate versus weather, and banks like that understand they are 
exposed to weather risks, and they understand what the big 
weather risks are, and they provision for them. And big weather 
events just have had no effect on our financial system and will 
continue not to have any effect on our financial system, 
because people know that is coming.
    Senator Toomey. Thank you.
    Dr. Zycher, your testimony recognizes the enormous 
complexities underlying climate models and projections. Is 
there any reason at all to believe that the Fed is in a better 
position to navigate these uncertainties and resolve these 
challenges as opposed to other public and private sector 
entities?
    Mr. Zycher. No, there is no reason at all. Neither the Fed 
nor the SEC nor other financial regulatory institutions have 
particular expertise in this area. Inevitably, they would rely 
upon analyses conducted at the EPA or other agencies' analyses 
that themselves are deeply politicized as they have been, you 
know, through the last several decades. And I think that there 
is no particular reason to believe the Fed would add to the 
stock of knowledge on these matters.
    Senator Toomey. And do the climate models, as you know of 
them, are they capable of telling us anything meaningful about 
near-term financial risks?
    Mr. Zycher. Well, the climate models are not designed to do 
that. They are designed to incorporate a set of assumptions 
yielding predictions about temperatures and other climate 
phenomena--sea levels and the rest--over a horizon of between 
50 and 300 years. That is what the climate models do. And with 
one or two exceptions, they do it very poorly.
    Senator Toomey. Now, if weather risks are material for any 
particular public company, isn't it true that current SEC 
regulations require full disclosure of those material risks?
    Mr. Zycher. Well, I am not really an expert on the SEC 
materiality requirements, but my understanding is that the 
answer is yes; if there is strong data suggesting that there is 
a risk to profitability, then the SEC framework requires that 
those be disclosed.
    Senator Toomey. And do you think it would be a good idea 
for the SEC to require nonmaterial risks, nonmaterial in the 
sense that they do not bear any risk to the financial 
performance of the company?
    Mr. Zycher. No, I do not believe that would be wise at all, 
and the broader point is that the disclosure of climate risks 
is so speculative that it is difficult to define it as 
material. That is the central point.
    Senator Toomey. All right. Thank you very much.
    Thank you, Mr. Chairman.
    Chairman Brown. Thank you, Senator Toomey.
    Senator Tester of Montana is recognized.
    Senator Tester. Thank you, Chairman Brown. I want to thank 
all the witnesses for being here today. There have been 
multiple hearings going on today, so it is tough to be in two 
places at once.
    But this is an important issue for me. I am a third-
generation farmer. I have a real job outside the Senate, and I 
will tell you that I have seen the impact of climate change 
firsthand. It is undeniable: longer, hotter summers; flooding; 
droughts. I have been on the farm since 1978, and I have seen 
things happen the last 25 years that my father never saw 
happen, and my grandfather certainly did not either. And I 
think that it is something that is real, and I think it is 
something that does impact people's financial decisions and 
banks' financial decisions as to whether they are going to loan 
money or not. And if we do not at least make some strides 
toward how we are going to deal with climate, I think we are 
going to lose family farms. I think we are going to lose our 
ability to feed this Nation, and that is not a pretty sight, in 
my opinion.
    So this is a question for Mr. Gelzinis. Could you describe 
to me the impacts we have already seen in the financial sector 
from severe climate-related events? Or have we not seen any 
impacts in the financial sector?
    Mr. Gelzinis. It is a great question, Senator. So one of 
the impacts that we have seen is on insurance company losses. 
So over the past 5 years, on average, there have been over $100 
billion of losses for insurers. If you go back, you know, 40 
years, the annual average was less than $50 billion. So that 
has significantly increased.
    So one of the reasons why I bring up insurance is because 
if those insurance companies start pulling out of business 
lines or geographies, given the 1-year policies, then all of a 
sudden the bank that thought it was protected against some of 
these risks because it had a good insurance policy on its 
longer-term asset no longer is. So we are starting to see those 
physical risks, you know, creep in, and there are examples on 
the coast as well.
    Senator Tester. So I want to talk to you about an area that 
you may or may not be familiar with, and that is crop insurance 
that is something that is backed by the American taxpayer. 
Something that, by the way, as a farmer, is absolutely 
necessary that we have this, especially with climate change.
    Can you tell me moving forward, from your point of view, is 
the taxpayer going to be putting more and more money into crop 
insurance? Or do you think that will be static because of 
climate?
    Mr. Gelzinis. So that is a little big outside my remit, but 
I am happy to follow up with you and your staff, Senator.
    Senator Tester. I appreciate it. I can tell you that with 
the uncertainty that I see, I think that it is going to require 
more and more subsidy moving forward. But I would love to hear 
your opinion on that moving forward.
    Look, I think we need to do a better job understanding the 
risks posed to our economy by climate. We need to have 
information on how to address these challenges that come along 
with climate change. Consumers and investors deserve to know 
how companies are exposed to these risks, what they are doing 
to mitigate climate risks, and that means looking to the 
future.
    I think disclosure and transparency is very, very 
important, whether it is corporate political spending or the 
impacts of climate change on businesses.
    Mr. Gelzinis, how important do you think access t 
information about potential impacts of climate change is for 
investor decisionmaking?
    Mr. Gelzinis. It is critical. Think about the SEC's mission 
to protect investors, to promote fair, efficient, and orderly 
markets, and, you know, from capital formation, how are 
investors supposed to do that if they do not have the necessary 
information on climate-related risks that are of such a 
magnitude that if they do not have those risks and those risks 
are hidden, we are going to get overinvestment in certain 
areas, underinvestment in others. You know, capital is going to 
be inefficiently allocated, and folks are going to lose 
confidence in both the transparency and resilience of our 
capital markets.
    Senator Tester. Are you concerned about the risks posed to 
our economy by the climate change issue?
    Mr. Gelzinis. Absolutely. Nearly every sector of our 
economy is going to be impacted in one way or another.
    Senator Tester. All I would like to say is--well, I just 
came from a Senate Veterans' Affairs Committee meeting when I 
turned it one, and it may be nomenclature, but the first thing 
I heard was, ``We know what the weather is going to be like for 
the next 4 or 5 years.'' Hell, I do not know what the weather 
on my farm is going to be like for the next 4 or 5 days. So we 
have got some challenges out there.
    I want to thank all the witnesses for being here on this 
panel.
    Chairman Brown. Thank you, Senator Tester.
    Senator Hagerty from Tennessee is recognized for 5 minutes.
    Senator Hagerty. Chairman Brown, Ranking Member Toomey, 
thank you for holding this important hearing, and I want to 
thank all of our witnesses who are present today to give us 
their perspectives on climate change.
    A lot of so-called environmental, social, and governance--
ESG--focused investing is concerned with climate change. So 
this hearing is also a really good opportunity to point out the 
hypocrisy of many of these supposedly ESG-focused funds when 
they fund through their investments the Chinese Communist 
Party's human rights violations against the Uyghur ethnic 
minority population, as well as funding China's economic 
practices that distort global markets and China's companies 
that lack transparency and accountability.
    Our financial regulators should certainly be focused on the 
resilience of our financial system, but as others have noted, 
they do not have the jurisdictional authority nor do they have 
the institutional capacity to regulate in the area of climate 
change.
    We should not be imposing any unnecessary constraints on 
our financial institutions' lending or excess costs on our 
public markets participants. Nor should we be enacting policies 
that would undercut hard-won American energy independence that 
would raise our energy costs or that would eliminate American 
jobs. This is especially the case now as we look to continue to 
fully rebound from this pandemic- induced economic recession as 
quickly as possible.
    What I would like to do is turn my questions to Dr. Zycher 
and Dr. Cochrane. I appreciate your focus on ensuring that 
regulatory oversight in our financial system is not used to 
advance a simple liberal socialist agenda. We currently have 
deep and sophisticated pools of private capital and private 
markets to deal with potential catastrophic risks that are both 
weather- and climate- related.
    For example, our property and casualty reinsurance markets 
underwrite hundreds of billions of premiums annually. In fact, 
according to S&P, most of the top 20 global reinsurers 
increased their exposure to property catastrophic risk last 
year. So I am going to ask these questions of both of you, Dr. 
Zycher first, then Dr. Cochrane.
    In your view, whether through risk-sharing instruments or 
other long-term capital planning devices, does the private 
sector have tools and incentives for making sound business and 
risk management decisions concerning potential climate risks?
    Mr. Zycher. You know, I see no reason to believe that the 
private sector has inefficient incentives in terms of adjusting 
to perceived risks. What is being advocated by many people is a 
top-down approach to forcing the evaluation of these risks by 
the financial sector. I think it would be much wiser to use a 
bottom-up approach in which the market makes whatever judgments 
about these risks that it deems appropriate and then prices 
those into the products for insurance services or other things 
that prove efficient.
    Senator Hagerty. Dr. Cochrane.
    Mr. Cochrane. You know, weather comes and goes. We do not 
know if it is going to rain or snow tomorrow, but we know 
pretty much what the range of weather can be. Climate is about 
changes in that range of weather, and we know that in the next 
5, 10, even 20 years, the change in weather is not going to be 
that big. People whose businesses depend on the weather make 
pretty good assessments of how bad the weather can be. And 
weather is just a small part of the U.S. economy. So the risk 
is small, and it is well modeled by people who have that risk.
    Senator Hagerty. Yeah, in fact, the sophistication of those 
that do model the risk--and, again, billions of dollars are 
moved into capital markets to address weather- related risk--
very highly sophisticated modeling that takes place.
    My second question, again, to Dr. Zycher first, then I will 
come back to you, Dr. Cochrane: Ranking Member Toomey already 
touched on this a little bit earlier with you. Are you more 
comfortable with financial regulators wading into this area or 
with, again, for example, private insurers that have expertise 
in modeling and assessing catastrophic risk exposures, 
educating shareholders on risk, and creating tailored 
solutions? Which would you be more comfortable with: financial 
regulators or the private market participants that are in this 
business?
    Mr. Zycher. You know, I do not think there is much question 
that such risk evaluation by the private sector would be much 
more unbiased and much more efficient. Insurance companies and 
others have powerful incentives to evaluate these risks and are 
much less subject to political pressures, litigation threats, 
and regulatory mandates than is the case for the Fed or the SEC 
and other top-down agencies issuing edicts in a top-down 
fashion.
    Senator Hagerty. Yeah, well put. Dr. Cochrane.
    Mr. Cochrane. I would not mind if our financial regulators 
were looking at all sorts of the out-of-box risks, but they are 
not looking at all the big ones, and they are looking at one 
that is basically made up.
    Let us also remember financial regulation is not about the 
proposition that nobody can ever lose money. Financial 
regulation has to be just about will banks fail, will there be 
a crisis, and we seem to have slipped into the idea that nobody 
can ever bear any risk anymore.
    And, finally, remember, the worst-case economic scenarios 
for climate is 7 percent to 10 percent of GDP in 100 years, a 
tenth of a percent per year. And that is the worst case. Ben 
will explode with how much that has the thumbs on the scale. So 
over the horizon we can think about things, this is a small 
risk to the U.S. economic and financial system. Sorry. That is 
a fact.
    Mr. Zycher. Senator, if I may add something, the major 
integrated climate economy assessment model predicts that by 
the end of the century, across policy scenarios, the 
differences in GDP for the U.S.--not GDP growth but GDP--in 
absolute dollars would be about 3 percent by the end of the 
century. The effect of these risks is much smaller than is 
commonly asserted.
    Senator Hagerty. Thank you.
    Chairman Brown. Thank you, Senator Hagerty.
    We will go next to Senator Menendez. I am going to duck out 
for 5 to 10 minutes to go to the Finance Committee, so it will 
be Senator Menendez, then Senator Daines of Montana, then 
Senator Warner of Virginia. So that will be the order if I am--
when I get back. So please proceed, Senator Menendez, for 5 
minutes.
    Senator Menendez [presiding]. Thank you, Mr. Chairman.
    More than 8 years ago, Superstorm Sandy crashed onto New 
Jersey's shoreline, causing the greatest natural disaster in 
our State's history. It caused billions of dollars in damage, 
including some sustained damage to home values. A large share 
of homeowners' wealth is locked up in their homes, and 
homeownership is the most important and accessible way to build 
wealth. And climate change increases the frequency and 
intensity of storms like Sandy and endangers, I think, the 
cornerstone of wealth building. If due to climate change these 
homes become uninsurable and unmarketable, the value of these 
homes and the wealth of homeowners is at risk.
    So, Mr. Gelzinis, as storms like Sandy increase in 
frequency and severity, do you expect coastal homes to lose 
value relative to the balance of homeowners' mortgages, causing 
these mortgages to become financially underwater?
    Mr. Gelzinis. Thank you for the question, Senator. So to 
the extent that they are exposed to rising sea levels and 
increasingly severe frequent floods and extreme weather events 
like Sandy, those homes will lose value as the physical impacts 
of climate change intensify and threaten to damage those 
properties. There is some evidence that those risks are 
starting to make their way into house prices in certain coastal 
geographies already. And, of course, whether a specific home is 
driven underwater will depend on the level of home equity and 
the extent of the damage the home is vulnerable to, but it is 
certainly possible, especially under the most severe warming 
pathways, that climate effects could drive up a large swath of 
coastal homes and put them underwater financially.
    Senator Menendez. Well, according to one report, New Jersey 
has lost $4.5 billion in home value since 2005, a time period 
covering Sandy, because of flooding related to sea level rises. 
So it is just one dimension, I think, of the challenge before 
us.
    Under current rules, public companies are not required to 
disclose political spending to shareholders. As a result, 
corporate executives can spend investor money on political 
causes without any consideration for shareholder views or the 
company's public commitments to climate- friendly initiatives.
    Mr. Gelzinis, should shareholders of public companies that 
make carbon-neutral or other climate-friendly pledges expect 
their company to act in a manner consistent with that stated 
company policy?
    Mr. Gelzinis. Yes, Senator, a public company's shareholders 
should absolutely expect that a company's actions will align 
with pledges or other public commitments.
    Senator Menendez. Well, in 2017, while companies publicly 
stated that the U.S. should remain in the Paris climate accord, 
many spent shareholder money to oppose the very essence of what 
they were saying; and because there are no disclosure 
requirements, their shareholders had no way to know.
    So do shareholders have the right to know whether their 
company's political donations contradict their public 
commitments and whether those companies may be supporting 
outcomes that might pose a material risk to the company's 
bottom line.
    Mr. Gelzinis. Senator, shareholders do have the right to 
know whether the company's political spending is consistent 
with the publicly stated policy of the company. We have seen 
plenty of examples of companies that have said one thing 
publicly and spent shareholder dollars to advance contradictory 
goals in the political process. That creates material 
reputational harm and can certainly impact performance. And I 
would just note that your efforts around the Shareholder 
Protection Act have been critical. The bill would give 
investors both the transparency they need and the ability to 
hold companies accountable.
    So the SEC really must center disclosure requirements on 
the information investors need, and investors have made it 
abundantly clear that this information is important to them.
    Senator Menendez. Thank you. Now, when we talk about 
systemic financial risk due to climate change and ensuring that 
companies are transparent about those risks in various filings 
and disclosures, we are really talking about two kinds of 
risks. There are risks to physical assets that can be impacted 
by various climate events, like extreme weather and sea level 
rise, as well as risks associated with our transition away from 
a dirtier, more polluting form of energy toward a clean 21st 
century economy. That transition brings some extraordinary 
opportunity to create new middle-class jobs and reinvigorate 
our manufacturing and energy sectors. But at the same time, 
investors and financial institutions have to understand the 
market risks associated with carbon-intensive industries as the 
U.S. and the rest of the world moves toward a zero emission 
economy.
    Dr. Keohane, as the SEC looks to revamp its climate risk 
disclosure requirements, how can these rules better speak to 
both physical and transitional risks associated with climate 
change? And how do we best quantify those risks?
    Mr. Keohane. Well, thanks very much Senator, for the 
question. The first thing I want to say is the reason we focus 
so much on climate risk disclosure is because transparent 
information is a fundamental aspect and a requirement, a 
condition, for an efficient market. I think Dr. Cochrane and 
Dr. Zycher know this, but we are not talking about directing 
allocation of capital. We are talking about allowing investors 
to know what they are investing in and to give them that 
information.
    And to your question, Senator Menendez, we focus on three 
criteria that we think the SEC should look to when it 
strengthens mandatory disclosure of climate risk.
    The first is information should be comparable. Investors 
need to know how corporations compare with one another in terms 
of the risk and performance both with respect to that 
transition risk, Senator, as well as with respect to exposure 
to physical risk.
    Second, the disclosure needs to be specific, the 
information that is particular to the corporation. Too often we 
just see generic language and sort of boilerplate language. 
That has been the result of several studies that have found 
that.
    And the third is decision-useful. It needs to be relevant 
to the decisions that investors are making, and so comparable 
specific decision-useful information is what the SEC should 
mandate companies disclose.
    Senator Menendez. Thank you.
    I understand by the Chairman's order Senator Lummis is 
next.
    Senator Lummis. Thank you very much.
    My first question is for all of our witnesses, and it is a 
simple yes-or-no answer. The question is: Did Operation Choke 
Point damage our financial system? And I will start with Dr. 
Cochrane.
    Mr. Cochrane. I have not studied it enough to be able to 
comment for you. Sorry.
    Senator Lummis. Thank you. Dr. Zycher.
    Mr. Zycher. Yeah, I think that Operation Choke Point was 
deeply corrosive to the rule of law and our constitutional 
institutions. It was a blatant attempt to bypass Congress and 
implement a politicized allocation of credit in a way that 
disfavored politically unpopular industries.
    Senator Lummis. Thank you.
    Ms. Waite, do you have an opinion about Operation Choke 
Point?
    Ms. Waite. I also have not studied it enough to have an 
opinion about this. Thank you.
    Senator Lummis. Mr. Keohane? And excuse me if I have 
butchered your name.
    Mr. Keohane. That is OK, Senator. I am afraid I am in the 
same boat as Dr. Cochrane and Ms. Waite.
    Senator Lummis. And, Mr. Gelzinis.
    Mr. Gelzinis. Senator, I cannot speak to the Department of 
Justice portion, nor the specifics of some of the financial 
regulatory actions. I would just say, though, that it is 
important to remember that reputational risk is financial risk.
    Senator Lummis. Well, thank you. I am going to then ask Dr. 
Zycher to respond further on this point. To me, the climate 
change-related proposals being discussed sound a lot like 
Operation Choke Point, and so to Dr. Zycher--actually, it was 
Dr. Cochrane, wasn't it, who responded earlier? Why is that? 
Why do these sound so much alike?
    Mr. Cochrane. I am not good on the details of Operation 
Choke Point. I am going to be hard pressed to make a 
comparison. I can fulminate all you would like on proposals of 
regulating and disclosing fictitious climate risks on their own 
basis.
    Senator Lummis. So it is Dr. Zycher that I want to ask to 
respond. You can see the tie I am trying to make, I hope, Dr. 
Zycher.
    Mr. Zycher. Yes. I made the point in my formal statement 
submitted to this Committee and in very brief passing during my 
oral comments a few minutes ago that the risk disclosure 
requirement, given the biases to which the financial sector 
would be subjected, amounts to a blatant effort to distort the 
allocation of the capital away from certain industries on the 
basis of the ideological goals of certain political interest 
groups. That is exactly what we observed during Operation Choke 
Point, and so the proposals being made here today by some of 
the Senators and some of the witnesses that the Fed and that 
financial institutions be required to disclose climate risks is 
an indirect but obvious way to distort the allocation of the 
capital away from the fossil fuel industry and perhaps others 
that are politically disfavored by certain ideological groups.
    Senator Lummis. And, further, do you believe that there is 
consensus on how we should mitigate climate risk in the 
financial system?
    Mr. Zycher. No, there is no consensus on the extent to 
which climate change is caused by man or is the result of 
natural phenomena. It is a combination of both. And I do not 
think there is any consensus certainly if we look at the 
disagreement being exposed during this hearing today about how 
risks should be measured, how they should be disclosed, what 
implications they should carry, et cetera, et cetera.
    Senator Lummis. Dr. Cochrane, would you also weigh in on 
this point? Do you think there is a lot of consensus?
    Mr. Cochrane. Climate change poses no risk to the financial 
system. This is a made-up risk. So there is no consensus in the 
sense that we are just asking banks to make up numbers to 
please regulators, and once banks are making up numbers of 
fictitious climate risks, then we lose the integrity of the 
financial regulation system. So there is consensus by people 
who want to push a particular agenda, but, you know, we are 
talking about a fiction here, not a fact. So you cannot have 
consensus on how to measure a fiction.
    Senator Lummis. Well, thank you all, witnesses, and for 
those of you who are unfamiliar with Operation Choke Point, 
which I confess I was unfamiliar with it, too, you might go 
back and look at it because I think that it is something worth 
referring to, and it is a cautionary tale as we engage in this 
discussion.
    Thank you, Mr. Chairman. I yield back.
    Chairman Brown [presiding]. Thank you, Senator Lummis.
    Senator Warren from Virginia--or Warner, from Virginia--I 
am sorry--is recognized for 5 minutes. I know the difference.
    Senator Warner. I know you sometimes get us mixed up, 
Sherrod. Listen, I appreciate the diversity of opinion on the 
panel, but I am little bit stunned by some of the commentators' 
indication that somehow climate is made up or fictitious. I am 
not going to fully engage on this other than the fact that I 
would clearly urge them to talk to the United States Navy, 
which is not viewed as kind of an out-of-the-ballpark group 
who--we are blessed in Virginia to have the largest naval base, 
and it is--we spend hundreds of millions of dollars a year 
raising the piers because of the threat from sea level rise. 
Whether you call that climate change or sea level rise, I do 
not call what you call it; it is affecting our naval base, 
Hampton Roads, the resiliency level. This is an issue that 
everyone of every political persuasion who lives this risk each 
and every day--and I am astonished that there are so-called 
experts that are denying the validity of what is happening 
real-time in my State. Again, we ought to have a lot of 
different opinions.
    I would like to go to the market questions now, and, Mr. 
Chairman, I have got right here--I am trying to make sure I am 
watching my numbers. This is the GAO study that I requested 
back in 2018. It came out in 2020. I ask unanimous consent that 
it gets submitted for the record.
    Chairman Brown. Without objection, so ordered.
    Senator Warner. Mr. Chairman, this GAO study uncovered that 
12 out of 14 institutional investors seek information on ESG--
environmental, societal, and governance--metrics to understand 
risk and assess long-term financial performance. These 
institutional investors find that as they look at the long-term 
financial risk--and these are not mandated by the SEC, although 
I am happy to say that the SEC is doing a study on this matter. 
But they have not mandated. These are institutional investors 
who say, ``We need this information because we believe as 
institutional investors that climate is providing a long-term 
financial risk.''
    As a matter of fact, BlackRock just last night, BlackRock 
that I know, Mr. Chairman, is one of your favorite 
organizations, somebody that you have not always agreed with, 
but BlackRock came out last night saying they think we ought to 
have mandatory financial reporting on environmental risks. So 
while I know some of the members of the panel may want to 
dismiss this science or somehow say that it is simply being 
promoted by the political interests, I actually call BlackRock 
and 12 out of the 14 institutional investor groups of the GAO 
study examples of where the market is demanding this 
information so that institutional investors on behalf of their 
long-term pension shareholders and others can have this 
information as they make the kind of long-term assessments, 
because, otherwise, the rate of return to those investors is 
going to be diminished by the effects of what we call climate 
change, sea level rise, weather changes. You call it and name 
it, but it is out there and it is real.
    Mr. Gelzinis, you have talked in your testimony about the 
need for ESG metrics. Can you talk about how not having robust 
disclosure requirements on ESG actually puts American companies 
at a competitive disadvantage against other companies around 
the world that have to make these kind of reports?
    Mr. Gelzinis. Thank you for the question, Senator. So if 
the SEC fails to integrate climate-related risks into its core 
regulatory framework, investors will be exposed to risks that 
were not sufficiently disclosed to them, capital will be 
inefficiently allocated, and our markets will be anything but 
orderly. And that will serve as a drag on capital formation due 
to a loss of investor confidence in the resilience and 
transparency of our markets.
    So essentially a failure to address these issues here in 
the United States would undermine the health and attractiveness 
of our capital markets globally. But if other major markets in 
the world are modernizing and providing investors with the 
information they need to efficiently allocate capital and we 
are not, it is going to put U.S. companies at a disadvantage.
    Mr. Cochrane. Can I just--as a matter of fact, nobody on 
this panel denied climate change. We all agree that climate 
change is real.
    Senator Warner. Mr. Cochrane, all I know is I just--I had 
not heard your whole commentary, but I heard you and Mr. Zycher 
indicate that somehow factoring in these standards would 
distort the market. And respectfully, sir, I could not--and I 
have spent--I get a lot of criticism from my Democratic 
colleagues as being too pro-market-oriented, and I can take you 
to parts of Virginia where we are grappling with this risk. And 
I think, quite honestly, when groups like BlackRock, when 12 
out of 14 institutional investors say we need these kind of 
metrics, and when we fail to have metrics that are actually 
commonly measurable between companies, we put American 
companies at a disadvantage.
    Thank you, Mr. Chairman. I hope that we will come back and 
be able to revisit this because I think it is a critically 
important issue.
    Chairman Brown. Thank you, Senator Warner.
    Senator Daines from Montana is recognized.
    Senator Daines. Yes, thank you, Chairman. Let me first say 
this hearing comes just weeks after the Biden administration 
canceled the Keystone Pipeline, and as a chemical engineer, 
somebody who believes in science, it is jaw-dropping. This is 
such classic virtue signaling, even though the pipeline is the 
safest way and most environmentally sound way to move oil, in 
fact, has the least amount of carbon emissions, because here is 
what is going to happen. If there is not a pipeline, it is 
going to be either through rail or by truck, which emits more 
carbon. I just wanted to lay that out there. We want to stay 
focused, I agree, on the science and the data as we look at 
this issue of climate and of risk. I urge the President to 
reverse this decision. It is reckless, it is devastating, it is 
bad for the climate, and it is even worse for our communities.
    I am concerned that what is really under discussion today 
is really not an effort to protect the financial system from 
climate risks but, rather, to establish conditions by which 
certain businesses deemed politically unfavorable can be 
starved of capital and shut out of the financial system. I 
joined Senator Cramer in introducing the Fair Access to Banking 
Act, which would prevent banks, prevent financial services 
providers from discriminating against law-abiding businesses 
such as oil, gas, and coal producers. In fact, we introduced 
this legislation after seeing private institutions succumbing 
to political pressure. That is wrong.
    I worry that a historically bipartisan agency such as the 
SEC might move aware from its mission that is supposed to 
protect investors, maintain fair and orderly efficient markets, 
and facilitate capital formation, and instead act to reshape 
the financial system in ways that I do not think themselves 
have really fully thought through.
    Dr. Zycher, can you tell me how mandatory climate 
disclosures will by itself decrease climate-related risks in 
the financial system?
    Mr. Zycher. I do not think that mandatory disclosures would 
have any such effect at all because it is not quite clear what 
would be required to be disclosed. What model would a financial 
institution use? What assumption would it make or be required 
to make about the sensitivity of the climate system to growing 
greenhouse gas atmospheric concentrations? What concentration 
would be assumed for the year 2100?
    The disclosure requirement being proposed would turn out to 
be so speculative and so subject to political pressures and 
litigation threats and other similar distortions that no useful 
information would, in fact, be provided to the market.
    Senator Daines. Thank you. I know this is not going to be a 
debate on climate change, and I think all of us agree there is 
climate change. It is a dynamic environment. It has never been 
static. It is either always going through natural cooling or 
warming trends. The real question is in this multivariable 
equation--and I guess I pride myself of having spent a lot of 
time studying thermodynamics, physics, chemistry, and so forth. 
What component of this is human- caused? It is very much one of 
the components. Let us all agree there are multiple variables 
in this equation.
    But I want to switch and ask a question of Dr. Cochrane. 
Can you tell me what ESG means in practice when it comes to 
index funds? Is there a standardized definition or is this just 
jargon?
    Mr. Cochrane. Well, it is marketing, and you can sell 
indulgences and charge a high fee. I think to your previous 
question, I just wanted to comment as well. I think you hit the 
nail on the head. We might be able to get companies to disclose 
carbon indirectly, but the proposal is to get them to disclose 
financial risks due to carbon, and that is the part that is 
made up.
    Senator Daines. Let me go to these ESG index funds. I have 
got a follow-up question. If we looked at the data from 
FactSet, exchange-traded funds explicitly focus on socially 
responsible investments and have a 43-percent higher fee than 
widely popular standard ETFs. And, in fact, the environmental, 
social, and governance funds' average fee was 0.2 percent at 
the end of last year, while your standard ETFs are at the 0.14 
percent average. That has a real impact on investors' bottom 
lines. In fact, according to one recent analysis, over a 10-
year period $10,000 in an ESG fund would be about 44 percent 
smaller compared with an investment in an S&P 500 tracking 
fund.
    Either Dr. Zycher or Dr. Cochrane, because I am running out 
of time here, why do ESG funds on average charge much higher 
fees than standard broad-based index funds?
    Mr. Cochrane. Because people are willing to pay them. You 
know, if people want to pay to feel good, that is their 
business. I am for free markets always.
    Mr. Zycher. I am not quite as cynical as John, even though 
he is so much younger than I am. I mean, an ESG fund by 
definition has to be actively managed in order to make sure 
that the underlying assets satisfy the politicized requirements 
of the ESG objectives. That means fees have to be higher than 
those charged for an index fund, which is not actively managed. 
And so if we believe the standard hypothesis, which I do, that 
securities prices always reflect all available information, it 
is very difficult to beat the market, and individual investors 
can approach that goal by minimizing fees--in other words, by 
investing in index funds. That is the central message from 
Burton Malkiel and other analysts. And I think that it is 
obvious why ESG funds charge higher fees. They are charging a 
fee to actively manage a fund in order to achieve a politicized 
goal.
    Senator Daines. Thank you. I am out of time.
    Thank you, Mr. Chairman.
    Chairman Brown. Thank you, Senator Daines.
    Senator Van Hollen is recognized for 5 minutes.
    Senator Van Hollen. Thank you, Mr. Chairman. Can you hear 
me OK?
    Chairman Brown. Perfectly.
    Senator Van Hollen. Good. Well, let me thank all the 
witnesses. Thank you, Mr. Chairman, for holding this hearing. 
And I agree that markets work best when investors and consumers 
have all available information, which is why it is troubling to 
hear some witnesses suggest that we should not be providing 
investors with information about the risks from climate change. 
As someone who would make an investment, I would think that we 
would want everybody to have information about what risks they 
are taking. That is why I am pleased to see the SEC moving 
forward, and the CFTC, and what they are doing is moving 
forward to study how best to measure those risks, because 
obviously we do need to standardize that approach. You are 
already seeing a lot of financial institutions in Europe begin 
to take those risks into account. They are real.
    Here is a quote from somebody who has been involved with 
the American Property Casualty Insurance Association: ```The 
alarm bells are now ringing loudly,' says Karen Collins, who 
handles home insurance and other personal lines for the 
American Property Casualty Insurance Association. `Climate 
change is leading to skyrocketing costs to insure and rebuild.' 
''
    You know, this is a statement from somebody who is directly 
involved in having to price in these risks, and it would seem 
to me that we would want everybody involved in that area to be 
informing investors and consumers about those risks, which are 
real.
    Mr. Keohane, I would like to ask you about the insurance 
companies because from Lloyd's of London to others, they have 
been very clear that prices are going to go up, but we do not 
know if they are yet at a place where they capture all the 
risk. Can you talk a little bit about the insurance industry, 
property and casualty insurance industry, and why it is 
important that we calculate these climate change risks?
    Mr. Keohane. Absolutely. Thank you, Senator, and I want to 
just express a note of appreciation for what you said about the 
importance of choice. We are talking about informing investors. 
We are talking about investor choice. I think it is puzzling to 
see folks saying we should not allow investors to have the 
information they need to make the choices they want.
    With respect to insurance, Senator, that was raised 
earlier, I think, by a couple of the other witnesses on the 
panel. I found that ironic that insurance was raised, private 
insurers were raised as the solution here. If you ask folks in 
California, they will tell you wildfire insurance is 
essentially no longer available. The California State 
government had to step in because wildfire insurance was not 
going to be offered anymore by private insurers. Why is that? 
It is because the uncertainties and the risk around climate 
change are changing--or as a result of climate change, are 
changing in ways that the insurers do not understand. With all 
due respect to Dr. Cochrane, the probability distributions are 
shifting. And when that happens the insurers, their response 
is, ``I do not know how to price this. I am going to get out.''
    So we are looking at--across a range of sectors, we are 
looking at what happened, frankly, with flood insurance in the 
1960s when the private insurers stepped out, and then the 
Federal Government has to step in. And what that ends up doing, 
when the Federal Government or a State government, as in 
California, is the last resort, that puts taxpayers on the hook 
for these risks. Obviously, someone needs to insure, but it 
would be much better if we had a system where there was clear 
and transparent information that investors need and that 
insurers need and that people making decisions about insurance, 
that they need as well.
    Senator Van Hollen. Well, that is right, and if that risk 
is not priced into these products, as you say, when the 
companies are unable to pay out on the insurance claims, it is 
the taxpayers who end up picking up the bill. We have already 
seen that when it comes to the flood insurance, and that is 
just getting even more so in that area.
    Let me ask you, Mr. Gelzinis, about stress testing other 
financial institutions like banks for this kind of a risk. 
Sarah Bloom Raskin, who is a Rubenstein Fellow at Duke 
University, has said that regulators should begin to collect 
data and create models that would enable them to carry out 
meaningful climate-related stress tests, again, to see if there 
are hidden risks which could explode and require taxpayers 
potentially to pick up the bill, at least if they are 
systemically important entities.
    So could you comment a little bit on that idea?
    Mr. Gelzinis. Yeah, I think stress tests could be a really 
important tool here, and I want to be very clear about what 
stress tests are and what they are not. Stress tests are not 
meant to predict the future, so a lot of what banks that have 
brought up opposing the establishment of these tests say, well, 
climate change is really hard to model and predict, so why 
should financial regulators try?
    The point is not to predict the precise outcomes here. The 
point is to test bank balance sheets against extreme but 
plausible scenarios. And so I think that is a hurdle the 
Federal Reserve and other financial regulators could meet to 
make sure bank balance sheets are resilient to these risks.
    Senator Van Hollen. Right. I think when we are talking 
about all this, we are trying to create standard models that 
are broadly accepted for assessing risk.
    Thank you all, and thank you, Mr. Chairman.
    Chairman Brown. Thank you, Senator Van Hollen.
    Senator Tillis from North Carolina is recognized for 5 
minutes.
    Senator Tillis. Thank you, Chairman Brown. Can you hear me?
    Chairman Brown. Yes.
    Senator Tillis. Thank you. Actually, I want to follow on a 
bit to the last conversation for Dr. Zycher and Dr. Cochrane. A 
2020 survey by the International Basel
    Committee on Banking supervision found that 10 of 15 
jurisdictions indicated, ``Current data are not sufficiently 
granular or reliable to feed into potential assessment 
models.''
    And another article in Nature Climate Change journal finds 
that, ``Calls for the integration of climate science into risk 
disclosure and decisionmaking across many levels of economic 
activity has leap-frogged the current capabilities of climate 
science and climate models by at least a decade.''
    There was another Politico article that was just talking 
about the reliability of information and transparency, 
accessibility to information that could help with certain 
assessments.
    So, Dr. Zycher and Dr. Cochrane, what sources are the 
relevant domestic and international regulators currently using 
to model climate risk?
    Mr. Zycher. Well, I think that what most public officials 
both in the U.S. and around the world are reduced to using are 
the reports from the Intergovernmental Panel on Climate Change. 
The assessment reports, the last of which came out in 2013, and 
the next one, the sixth report, will come out in 2022, and 
those reports are peer-reviewed; they are written by serious 
people, and there is enormous uncertainty, and to a significant 
degree, the conclusions both in terms of policy and climate 
science can be questioned quite significantly.
    There are other IPCC-type reports, for example, the 1.5 
Degree report that came out in 2019 that some people rely upon, 
it is just rather silly, frankly, in all kinds of ways and is 
not to be taken seriously.
    I think that the IPCC work is primarily what is used along 
with various Government reports and analyses by various 
agencies.
    Mr. Cochrane. I might add that they are making it up, 
because what we are talking about here is risk to the financial 
system, not even economic risk. And I think following the 
discussion you can see--so we talked about-- Senator Menendez 
talked about $4.5 billion of home value and some homes that 
went under in New Jersey. The stock market did not crash; banks 
did not fail. We talked about wildfires in California, which, 
yeah, that is a problem, almost all due to horrible forest 
management. Banks did not fail; the stock market did not crash. 
And we are ignoring the real risks--pandemic, war, Treasury 
failure, cyber attack.
    So the idea that it is a financial risk--and you can see it 
in the regulators. They are kind of floating around. It is 
mostly that we need to regulate this, but they really have no 
idea how.
    Senator Tillis. So what risk do we run if we move too 
quickly in modeling climate risk when there are questions about 
actionable and reliable data?
    Mr. Zycher. Well, we run the risk of leading the financial 
system toward distorting the allocation of capital in ways that 
are not productive, away from the fossil fuel industry and away 
from other sectors in response to analyses that are seriously 
distorted. That is one set of risks.
    We risk also ignoring the benefits of anthropogenic climate 
change, greening of the planetary ecosystem, greater water 
efficiency, greater agricultural production. There are benefits 
from increasing greenhouse gas concentrations, and we will 
ignore also, as I mentioned in my testimony, the risks of 
Government policies. Government policies cannot be predicted 
uniformly to yield positive results. Forgive me, Senators, but 
that is simply reality. And the central thrust of climate 
policy is an increase in energy costs. There is no way around 
that, and that will carry implications for the economy and, 
indeed, for the financial system that are not salutary.
    Mr. Cochrane. I would add we pollute financial regulation. 
Look, an honest bank, the size of the big banks, which is what 
is dangerous for the financial system, they put up the numbers 
correctly, they have to say, ``Look, climate does not pose any 
risk to us over the foreseeable horizon of our risks. But the 
regulators want to see something, so we have got to cook up 
some fictitious financial risks to make them happy and to give 
the answers they want.''
    Well, now the books have been cooked, and financial 
regulation against the real risks, the big ones that they do 
not see coming, then we will lose the power to do that, too. So 
it pollutes financial regulation as much as distorts the 
economy.
    Senator Tillis. I agree. Thank you.
    Thank you, Mr. Chair.
    Chairman Brown. Thanks, Senator Tillis.
    Senator Warren from Massachusetts is recognized for 5 
minutes.
    Senator Warren. Thank you, Mr. Chairman, and thank you for 
holding this hearing.
    There is just no more room to dance around here. The 
evidence is undeniable that climate change threatens our 
economy. In a speech last month, Federal Reserve Governor Lael 
Brainard said that climate change is already imposing 
substantial economic costs and is projected to have a profound 
effect on the economy at home and abroad.
    So, Mr. Gelzinis, how about if you connect the dots for us 
here? How does climate change put our financial system at risk?
    Mr. Gelzinis. Yes, thank you for the question, Senator. So 
the physical effects of climate change could devalue a range of 
real assets and financial assets, including commercial and 
residential real estate, corporate bonds and loans in certain 
sectors and geographies, municipal debt, commodities, and the 
derivatives tied to instruments. Then, in addition, the 
inevitable low-carbon transition could severely impair the 
value of financial instruments tied to carbon-intensive 
sectors. And both of these types of risks have not only 
microprudential implications for individual institutions, but 
also pose a broader systemic threat just given the magnitude of 
the risk, the types of firms exposed, and the potential speed 
with which these losses can materialize.
    Senator Warren. Thank you. You know, these risks are real, 
and they affect the safety and soundness of our financial 
system. The Federal Reserve currently supervises some of the 
country's largest banks, including the banks that have been 
designated as ``too big to fail.''
    So, Mr. Gelzinis, if the health of one or more of these 
banks was at risk due to climate change, would the Federal 
Reserve be stepping outside its mandate or expanding its 
mission if it treated climate change the same way it treats 
other risks to the financial system?
    Mr. Gelzinis. Absolutely not, Senator. It is clearly within 
their mandate.
    Senator Warren. Good. In other words, because the Fed's 
mandate includes the safety and soundness of the too- big-to-
fail banks, it is within the Fed's responsibility to deal with 
climate risk. And by ignoring climate risk, the Fed and other 
banking agencies are allowing politics rather than science to 
determine the course of their action. Is that a fair statement, 
Mr. Gelzinis?
    Mr. Gelzinis. Yes. I mean, the risks would violate the very 
responsibilities Congress handed down to the regulators.
    Senator Warren. And the biggest banks seem to realize what 
is happening, so they have started to brag about how great they 
have been doing to solve this problem all on their own. Last 
month, for example, JPMorgan committed to achieving net-zero 
carbon emissions by 2050.
    Now, I appreciate that commitment. I do. But we also know 
that JPMorgan has financed close to $270 billion in fossil fuel 
projects since 2016 and has yet to announce any clear steps as 
to how it will wind down its significant participation in oil 
and gas drilling, in fracking, and in other contributions to 
climate change.
    So let me ask: Mr. Gelzinis, is voluntary self- regulation 
from big banks sufficient to protect our financial system from 
climate risks?
    Mr. Gelzinis. So, Senator, when you were warning about a 
potential housing crash in the early 2000s, financial 
regulators and Wall Street executives at the time hailed the 
merits of self-regulation and cast aside the warnings of 
``alarmists'' since bank risk models and decisionmaking was so 
advanced that crises, you know, really were a thing of the 
past. Then the predictable catastrophe struck, and it was not 
those banks that caused the crash or regulators who were asleep 
at the wheel who suffered the consequences. It was communities 
across the country and the Government that picked up the tab.
    So financial firms simply do not have the incentive to 
self-insure against these risks, particularly against the worst 
outcomes, partly because of their near-term focus on quarterly 
profits and partly because they do not bear the full cost of 
the risks that, you know, their activities are placing on the 
system.
    So I guess my fear is that, you know, similar to 2008, 
while the music is playing, financial firms will get up and 
dance while they can still make short-term profits. They will 
continue to overengage in climate-risky activities until 
catastrophe strikes yet again and we relearn the painful lesson 
of self-regulation.
    So, anyway, that is just why I think it is so vital for 
financial regulators to step in here and ensure the financial 
system is resilient.
    Senator Warren. Right, and it is a powerful reminder of 
this analogy. You know, we need to take seriously the threat 
that climate change presents to our financial system, and that 
means using our regulatory tools to mitigate that threat. And 
every day that the Fed and other regulators refuse to do their 
jobs and ignore these risks, they put both our planet and our 
economy at risk.
    Thank you. Thank you for being here. And thank you, Mr. 
Chairman.
    Chairman Brown. Thank you, Senator Warren.
    The Senator from Minnesota, Senator Smith, is recognized 
for 5 minutes.
    Senator Smith. Thank you, Mr. Chair, and thank you to all 
the panelists.
    I am finding this conversation quite interesting, and I 
want to just start with a point here. I hear some of our 
panelists saying that it is so important, even some of my 
Republican colleagues saying how important it is that we 
address this from a public policy perspective, which I, of 
course, agree with. And so I would like to invite my colleagues 
on both sides of the aisle to join in the work that we have to 
do to address climate change from a public policy perspective.
    I am excited about the work that I am doing around a clean 
electricity standard, which would be a great example of the 
kind of thing that we could do to address climate change and 
get us to the clean green economy that I think that we know 
that we need.
    But let me turn to the topic here of this conversation, and 
I am going to direct this question I think to Mr. Gelzinis, and 
then, Ms. Waite, I have a question for you afterwards I would 
like to try to get to.
    Recently, our Republican colleagues sent a letter to Chair 
Powell questioning the need for assessing climate- related 
risk, saying, and I quote, ``Financial regulation does not and 
should not seek to guard against every type of unforeseen 
event.''
    So, Mr. Gelzinis, is climate change an unforeseen event?
    Mr. Gelzinis. No. It is a high-impact, high-probability 
event.
    Senator Smith. And will climate change affect asset 
valuations in the market?
    Mr. Gelzinis. Absolutely. It already is. And because of 
climate change's nonlinear effect, it is only going to get 
worse?
    Senator Smith. And is this a small risk, as some of our 
panelists have been posing? Or is it big?
    Mr. Gelzinis. No, it is a massive risk that impacts a wide 
range of asset markets, a wide range of financial institutions.
    Senator Smith. And isn't it the job of the SEC to protect 
investors and to maintain a fair and orderly efficient market? 
And wouldn't understanding that climate risk be an important 
part of their job, therefore?
    Mr. Gelzinis. Absolutely. Climate change intersects with 
each aspect of that mission that you just outlined.
    Senator Smith. And isn't it the job of the Federal Reserve 
to promote the soundness of financial institutions? And 
wouldn't that include understanding climate risk?
    Mr. Gelzinis. Absolutely. Both the safety and soundness of 
individual firms, which are undoubtedly exposed to these risk--
think, you know, a $20 billion bank in the oil patch or, you 
know, a $50 billion bank overly exposed to coastal real estate, 
but also given the magnitude, the stability of the banking 
system and financial sector as a whole.
    Senator Smith. Well, thank you for that. I think it is just 
important to clarify and understand what it is that we are 
talking about here. And so I appreciate that.
    Let me turn to Ms. Waite. You in your work at the 
foundation are talking about mobilizing private capital to 
address climate risk, and I want to just get your take on this. 
How would standardized climate risk disclosures support more 
efficient deployment of private capital to address the climate 
crisis? What impact would that have on how we are efficiently 
deploying private capital?
    Ms. Waite. So thank you for your question, Senator. Both 
investors and lenders rely on information to make decisions. So 
having this climate disclosure that the tons of carbon dioxide 
equivalent for each financial assets class disclosed--measured, 
disclosed, and reduced, that would enable investors and lenders 
to make better decisions to manage away from the carbon-
intensive assets toward the low-carbon ones.
    Senator Smith. Now, I think heard one of the panelists here 
today saying that some attempt to assess climate risk would--
first of all, that--he kept using the word ``fantasy,'' but 
what he seemed to be saying was that assessing climate risk 
would in some way distort the market. Could you explain--what 
do you think about that view?
    Ms. Waite. To the contrary, it would actually help protect 
the market and make better decisions so that we support those 
activities and financing those activities that do not put our 
financial system in danger. So it is actually the contrary. 
Actually, the market has spoken. One out of every $3 now 
invested in sustainable funds, investors are calling out for 
the ESG, ETFs have doubled in 2020 alone. Over 100 financial 
institutions or banks and asset managers are now measuring and 
disclosing the carbon emissions of their loans and investments. 
So this is happening.
    Now, it is the regulators' opportunity and job to actually 
step in and make sure that all institutions are doing this so 
that the entire system can work for this transition.
    Senator Smith. Well, thank you. I could not agree more. I 
appreciate all of you being here, and thank you very much, Mr. 
Chair.
    Chairman Brown. Thank you, Senator Smith.
    Senator Cortez Masto from Nevada is recognized for 5 
minutes.
    Senator Cortez Masto. Thank you, Mr. Chair. I appreciate 
this conversation.
    Let me start with Mr. Keohane and then follow through. 
Isn't it really true that at this juncture it is the investors 
that are demanding to know how companies are confronting the 
risks and opportunities posed by our changing climate and 
environment? Isn't that true that is what is happening today, 
right?
    Mr. Keohane. Yes, that is true. That is exactly right, 
Senator.
    Senator Cortez Masto. And so really it is the investors 
demanding--no matter what we want to say here as politicians in 
this room, it is the investors that are demanding to know this. 
Aren't they entitled to have this information?
    Mr. Keohane. Well, I certainly think so, Senator. As an 
economist, I think, you know, the free and transparent flow of 
information is critical to well-functioning markets and to 
investor choice. And I would say the only reason that 
disclosure would result in reallocation of capital away from 
fossil fuel companies is because investors might think there is 
a pretty big risk associated with investing in fossil fuel 
companies.
    But nobody is demanding that reallocation. It would be the 
result of investors making free and informed choices.
    Senator Cortez Masto. Thank you. Now, I am from Nevada, and 
our hospitality industry and tourism industry has been so 
devastated. Can you explain how investments in hospitality and 
tourism might be affected by physical and transition risk due 
to the extreme weather events brought on by climate change?
    Mr. Keohane. Well, Senator, I would be happy to get back to 
you with specifics around your State and hospitality. I will 
say in general that it is the shifting risks and uncertainties 
that have to do with climate change that present this risk. 
What we see--maybe one point I will draw on in this regard that 
the CFTC report I cited makes very clear. It is not only a 
question of risk to the entire economy, risk, you know, to big 
banks. It is also a question of concentrated geographical risk, 
what the report called ``sub-systemic risk,'' whether that is 
agricultural lenders, whether that is commercial real estate 
and small banks in coastal areas, or whether that is something 
like the hospitality industry in places that rely heavily on 
it.
    So it is those concentrated risks that mean there can be 
vulnerability and, I think Greg used the word, 
``microprudential'' issues associated with particular sectors 
or regions that are vulnerable to climate risk, and that is 
where there is a need for greater information and disclosure 
and regulation.
    Senator Cortez Masto. Thank you. And let me ask Mr. 
Gelzinis and Ms. Waite, do we actually have the modeling 
technologies we need to adequately evaluate the climate- 
related risk?
    Mr. Gelzinis. I will go first. I think they are certainly 
improving, but we will not get there if we do not get the 
underlying data that needs to fit into those models, which is 
another reason why disclosure is so important. And we certainly 
will not get there if regulators are not building up their own 
capacity.
    Senator Cortez Masto. Right. Ms. Waite, what do you think?
    Ms. Waite. I agree, and I would also add that in order to 
get the models in shape, the regulators have to request and 
demand the data. So the tons of CO2 for each financial asset 
class has to be disclosed for models to be built that actually 
gives a better sense of what is happening in the real economy 
through investments made by lenders and other investors.
    Senator Cortez Masto. Thank you. Thank you for this 
incredible conversation today.
    Mr. Chairman, I yield the remainder of my time.
    Chairman Brown. Thank you, Senator Cortez Masto.
    Senator Warnock from Georgia is recognized for 5 minutes.
    Senator Warnock. Thank you so very much, Mr. Chairman, for 
having this important and timely hearing on how we can address 
the impact of climate change on our financial system. I am 
grateful for all the panelists.
    I wanted to talk more about the climate-related impact on 
housing, particularly among communities of color. As you know, 
many Black and brown communities were once forced to purchase 
homes in less desirable neighborhoods and an unlawful practice 
that is known as ``redlining'' is a way in which that 
continues. These same communities are at higher risk of losing 
their homes to flooding caused by climate change. I think folks 
knew for a long time prior to Hurricane Katrina what happened 
in the old 9th Ward was predictable. We knew that when a storm, 
the right storm, came through that those folks were in an 
incredibly vulnerable position. And, again, communities of 
color were forced into these areas.
    A recent report examined nearly 40 metropolitan cities and 
concluded that homes purchased in these redline areas were 25 
percent more likely to suffer from climate-related flood damage 
compared to homes in non-redlined areas. Not only did the 
findings in this report confirm the racial disparities within 
our housing market, they also confirmed that these unjust 
lending practices have now presented significant concerns to 
our financial system.
    And so my question is for Mr. Gelzinis, Dr. Keohane, and 
Ms. Waite. How can Congress and Federal regulators-- what can 
we do to lessen the climate-related economic impact on 
historically disadvantaged communities and also on our overall 
financial system? What should we be doing in terms of public 
policy right now to take this issue seriously?
    Mr. Gelzinis. Great. Thank you, Senator. I just want to 
reiterate your point that it is all too clear that climate 
change just simply magnifies and exacerbates the racial 
injustice that is already embedded in our economic systems. So 
the same communities of color that were historically redlined 
now face the most severe physical risks like the flood risk 
that you mentioned, but also temperatures. Redlined parts of 
major metropolitan areas are several degrees warmer than other 
neighborhoods due in part to the lack of green space there.
    So in terms of policies, I think the Community Reinvestment 
Act is critical, and climate resilience and adaptation 
mitigation efforts should be integrated into the Community 
Reinvestment Act. I think the Community Development Financial 
Institution Fund that Treasury, the appropriation there could 
be increased and green criteria added as well to make sure 
community finance, particularly in communities of color, are 
helping finance the transition.
    Then it is outside the scope of my work, but I would just 
note that public finance and fiscal policy have a huge role to 
play here as well. And if disproportionate harms go to 
communities of color, then disproportionate funding needs to go 
to those communities of color as we build this new economy.
    Senator Warnock. Yes, Ms. Waite.
    Ms. Waite. So I will mention two things. The first is that 
the Federal Housing Finance Authority can do a lot. Fannie 
Mae's remarkably successful Multifamily Green Mortgage Program 
accounts for just over 20 percent of their multifamily 
mortgages. So the FHFA can expand these commitments to 
addressing climate change and climate resiliency.
    The second is to really ensure that the existing CRA, 
Community Reinvestment Act, explicitly calls out climate 
resiliency and climate change mitigation efforts. The other 
thing would be to create a new CRA mirror-like mandate on banks 
and other lenders so that they must lend a certain percentage 
of their assets into climate infrastructure in disadvantaged 
communities and communities that are likely to be impacted by 
climate change.
    Mr. Keohane. I will just basically echo what my colleagues 
on the panel have said, Senator. I think it is critical that we 
make more investment, both public investments with Government 
funds but also help leverage private investment, into investing 
in those communities, communities of color that have been 
historically burdened, that are more vulnerable to climate 
change, as you have said, but also have been historically 
burdened by pollution and toxic chemicals.
    So I think there is a huge amount of need there to direct 
funds and to make investments in coastal infrastructure and 
resilience, as my colleagues have said.
    Senator Warnock. Thank you very much. We have seen more 
recently financial regulators take more seriously the impact of 
climate on our larger financial system, but as you point out, 
we have got to do much more. So thank you for your insights.
    Chairman Brown. Thank you, Senator Warnock.
    Senator Toomey, before I close, do you have comments or 
another question or two?
    Senator Toomey. Mr. Chairman?
    Chairman Brown. Yes?
    Senator Toomey. Yeah, if you are going to make a closing 
statement, I would just make a brief statement.
    Chairman Brown. Sure.
    Senator Toomey. Would you like me to do that now?
    Chairman Brown. Yeah, sure. Please proceed. Thank you.
    Senator Toomey. Thanks for doing this hearing. Let me just 
say, you know, I believe that climate change is real. I think 
human activity is an important cause. But as Dr. Cochrane 
reminded us, climate change is not some unforeseen risk. It 
does not pose a risk to our financial system. And financial 
regulators who have no legal authority to regulate climate and 
have no expertise regarding climate change should not attempt 
to regulate a non-risk to our financial system.
    Let us be clear what this is really all about. This is 
about undermining the independence of regulators so that they 
can be pressured to allocate credit as the political left would 
like it to be allocated. Now, if people get their way on this 
and we start to have a political allocation of capital, that 
will result in slower economic growth, fewer jobs, lower wages, 
and a diminished standard of living. That is why this is a bad 
idea.
    Thank you, Mr. Chairman.
    Chairman Brown. Thank you. I will close in a moment. I have 
one more question. But we have heard about a lot of complex 
topics in this hearing. It is a big, complicated issue, of 
course. But to be clear, the Fed and other agencies cannot just 
care about what partners on Wall Street or professors at 
business schools or people at think tanks think is important. 
They have to look at factors outside the movement of money 
between and among banks. Look at something like cybersecurity. 
The Fed is not staffed with computer programmers, but we all 
agree it is part of their job--and several have said that in 
this hearing--to take on cyber risk.
    I want to end by bringing us back to why all this matters 
in people's lives. It is what I try to do at every hearing, on 
Tuesday with housing and again today, what it means when 
somebody is foreclosed on, what it means to a family.
    We know what climate can mean to paychecks and savings and 
communities. In Ohio, the combination of wetter springs and 
heavier rains and hotter summers has increased algae blooms 
across Lake Erie. It is the shallowest of the Great Lakes, and 
it is the most vulnerable in that way. Fewer tourists rent 
cottages or charter fishing boats, less money going to small 
business and supporting local communities in places like 
Sandusky, local economies and communities in places like 
Sandusky and Clinton and Lorain and Toledo. I hear it in 
conversations with people at Put-in-Bay on Lake Erie. It means 
less and less money in their pockets every summer.
    So I will close with asking Ms. Waite and Mr. Gelzinis and 
Dr. Keohane, could each of you just briefly, very briefly, talk 
about the moment you realized that climate change is going to 
affect people's jobs and local economies, and probably sooner 
than we think? Think back to the moment you first thought that 
and describe it briefly to us. Ms. Waite, if you would start?
    Ms. Waite. Yes, thank you, Senator, Chairman, for the 
question. I remember quite clearly in August 2005 when 
Hurricane Katrina hit, and that cost exceeded $150 billion. 
That was the first time I recognized that this was going to be 
extremely important for the economy and for the financial 
system.
    Chairman Brown. Thank you, Ms. Waite.
    Mr. Gelzinis. So for me personally, Mr. Chairman, it was 
really a compounding effect of the increasingly severe and 
frequent extreme weather events around us and really coming to 
understand that decarbonization was going to fundamentally 
restructure the economy. So I think when you have an issue as 
wide-ranging and of that magnitude, anyone working in public 
policy should ask: Does this issue intersect with my work? And 
the answer here was quite clearly yes.
    Chairman Brown. Dr. Keohane.
    Mr. Keohane. Thank you, Chairman. I have devoted my career 
to working on climate, but I guess if there was one particular 
instance that made me really realize the nature of extreme 
weather, it was Superstorm Sandy. I live in New York City. The 
city shut down, and then we saw the devastation out on Long 
Island and in New Jersey, which Senator Menendez referred to. 
So that was for me a moment where it really hit home.
    Chairman Brown. Thank you very much, Mr. Keohane.
    Senator Ossoff has appeared, and he will have the last 5 
minutes for questions. Senator Ossoff from Georgia, please 
proceed.
    Senator Ossoff. Thank you, Chairman Brown, and thank you to 
our panel.
    Mr. Gelzinis, what do you assess to be the most significant 
risks to financial stability or the financial system that are 
associated with climate change?
    Mr. Gelzinis. So the issue that I think, you know, would 
really be catastrophic is a simultaneous or near-simultaneous 
transition and physical risk event. So let us say, 
unfortunately, policymakers or regulators delay taking the 
necessary legal and regulatory steps to decarbonize; climate 
change continues to get worse; and then we have a brutal string 
of natural disasters and extreme weather events over, let us 
say, 18 months across the country, starting to erode the 
resilience of financial institutions. And then that spurs 
public action to rapidly decarbonize the economy and make up 
for the lost time that occurred before, devaluing a whole host 
of carbon-intensive assets that financial institutions had not 
started to wean down and bolster their resilience to, and so 
you would have both physical and transition effects impacting 
the financial system at the same time, potentially 
destabilizing it.
    That is the thing that would scare me the most.
    Senator Ossoff. Thank you. Could you please unpack in a 
little bit more detail the chain of events and financial 
instruments, mechanisms, asset classes, relationships that in 
such a high-stress event could cause there to be systemic risk 
to the stability or solvency of major financial institutions?
    Mr. Gelzinis. Yes, there are multiple ways that this could 
play out. So, first off, any risk to a systemically important 
financial institution, a too-big-to-fail bank, automatically 
becomes a macroprudential concern or a financial stability risk 
concern, because if one of those big banks failed, it is going 
to bring down the rest of the system with it.
    But you could also have correlated stress across a range of 
financial institutions, so let us say you had, you know, a 
range of $70 billion to $300 billion banks that were overly 
exposed to carbon-intensive sectors that led to, you know, as 
former Bank of England Governor Mark Carney noted, a ``climate 
Minsky moment'' where the carbon bubble bursts. There are rapid 
sell-offs and fire sales, impaired assets. Creditors start to 
run from the institutions that they think are exposed to those 
risks but may not have the transparency to know which 
institutions they are, so they pull out from a lot of 
institutions. And then that creates the first and second order 
effects that we know occur with, you know, financial crises and 
would impact financial institutions that were not even exposed 
to that climate-related shock in the first place.
    Senator Ossoff. Thank you. And in what ways and for what 
reason do you believe that markets are not currently accurately 
pricing such risks?
    Mr. Gelzinis. So I would say two things about that, 
Senator. So the first is institutional investors, when they are 
polled on this, all--I think it was over 90 percent said that 
they do not think that these risks are being appropriately 
priced in because they do not have the data and the information 
to price them in.
    The second point I would make is that even if risks were 
priced in, there would still be an important role for financial 
regulators to play around tail risks. So if you think about 
what it means to price in a risk, it means you have, you know, 
a weighted distribution of probabilities, and oversimplifying 
here, but you pick the median expected outcome and price it 
based on that. So financial regulators would still have a role 
to play in some of the tail scenarios that could play out with 
both the physical and transition risk that, you know, climate 
change poses.
    Senator Ossoff. I want to return to the previous question 
briefly, and I think one of the things I am trying to unpack 
here is whether we are talking about addressing risks to 
financial stability resulting from shocks associated with 
climate change or whether we are talking about economic policy 
and macroprudential policy as a means of mitigating and 
combating climate change, both of which I think could have 
merit as policy strategies.
    But can you please unpack for me again, with a little bit 
more specificity, how, for example, a series of severe weather 
events or climate-associated shocks could cause such stress in 
financial markets or such a precipitous reduction in the value 
of certain assets that it could pose a threat to systemic 
financial stability?
    Mr. Gelzinis. Sure. So one example that I would use is go 
back to Hurricane Andrew in the early 1990s. Insurance 
companies were looking--you know, they did not have advance 
catastrophe risk models at the time. They were kind of 
ballparking prices based on what they had always priced that 
risk at. Then all of a sudden, something happened that they 
were not expecting, and it wiped out 16 insurance companies. At 
the time we did not really have global interconnected insurance 
companies like AIG, but imagine if, you know, some sort of 
climate event on a much larger scale, if we had a couple 
hurricanes in the Southeast, wildfires raging in the West, and 
droughts and pests reducing crop yields in the Midwest. If that 
erodes the resiliency and drives losses at systemically 
important interconnected financial institutions like an 
insurance company or a major Wall Street bank, then the risk 
factor would be very similar to the financial crises we have 
seen in the past in terms of runs, fire sales, and a credit 
contraction for the real economy.
    Senator Ossoff. Thank you. I appreciate that. I am sadly 
out of time. Something I would like to address to all the 
panelists for the record, you mentioned crop yields, and I 
think that one of the things I would like to unpack a bit more 
is the impact on price stability and the impact on political 
stability that could result from effects on agriculture from 
some of the modeled climate scenarios. But, alas, I do not have 
the time right now, and I see Mr. Cochrane is shaking his head, 
eager to address that question for the record. So you will all 
have the opportunity to do that.
    I thank you again for being here today, and I yield back, 
Mr. Chairman.
    Chairman Brown. Thank you, Senator Ossoff.
    Thanks to the witnesses for being here today and providing 
testimony. For Senators like Senator Ossoff who wish to submit 
questions for the record, those questions are due 1 week from 
today, on Thursday, March 25th. For witnesses, you have 45 days 
to respond to these questions.
    Thank you all for your participation and your civic-
mindedness. The Committee is adjourned.
    [Whereupon, at 12:12 p.m., the hearing was adjourned.]
    [Prepared statements, responses to written questions, and 
additional material supplied for the record follow:]
              PREPARED STATEMENT OF CHAIRMAN SHERROD BROWN
    Today, the Banking and Housing Committee is holding its first-ever 
hearing on the risk climate change poses to our economy.
    That also makes it the first time our Committee will consider all 
the economic opportunities that exist by addressing climate change.
    More than ever, people in Ohio and around the country are 
experiencing how climate change affects their lives--from devastating 
hurricanes to raging wildfires, from harmful algal blooms in Lake Erie, 
to landslides in Cincinnati, to erratic farming seasons across the 
Midwest.
    People aren't stupid. They see what's happening, and they know it 
threatens not only their air and their water, but their livelihoods and 
their homes.
    And they also know that there are all sorts of opportunities, in 
communities in every state that come with taking climate change 
seriously.
    They see the wind turbines across the Great Plains made with 
American steel. They see people installing solar panels made in Toledo 
at one of the biggest solar energy manufacturers in the country.
    We can't have a 21st Century economy built on a 19th Century 
model--that doesn't make environmental sense. It also doesn't make 
economic sense.
    If we want an economy that creates jobs and improves infrastructure 
in all communities, and allows our businesses and our workers to 
compete around the world, then instead of running from these 
opportunities, we have to seize them.
    I want to be clear: it's not the role of this committee to vilify--
or even prop up--any specific technology or any source of energy. The 
work of coal miners in Belmont County, Ohio has every bit as much 
dignity as the work of a battery manufacturer in Fremont, Ohio.
    We show those workers no respect if we don't plan now for how we're 
going to protect their communities from flooding and drought and 
economic upheaval, and protect their retirement and kids' college 
savings from risky investments.
    On this Committee, we're charged with looking at anything that 
could hurt the stability of our economy.
    This is a set of issues my Democratic colleagues have talked about 
for a long time.
    And a lot of what we'll talk about today got a jump start last year 
when now-Acting CFTC Chairman Rostin Behnam created his Climate-Related 
Market Risk Subcommittee.
    The Subcommittee put out an important report, ``Managing Climate 
Risk in the U.S. Financial System.''
    And just yesterday he announced he's establishing a Climate Risk 
Unit (CRU) in CFTC to focus on the role of derivatives in 
understanding, pricing, and addressing climate-related risk.
    I would like to ask unanimous consent to enter the CFTC 
subcommittee report, ``Managing Climate Risk in the U.S. Financial 
System,'' into the record for this hearing.
    Being on the lookout for risk is our job here.
    We can't always predict what it might be--it could be the business 
decisions of a few bad actors in a particular industry. Or we might be 
forced to act because of events beyond our borders.
    In this case, though, we can predict something that's going to hurt 
the economy. We know that climate change threatens the country's 
financial stability.
    And the financial sector, and the government agencies that oversee 
it, are going to have to reckon with the consequences of decades of 
risky investments in industries that fuel natural disasters, and 
threaten people's paychecks and their retirement security.
    For years, the biggest corporations have fought government action 
on climate change because CEOs could make a lot of money in the short 
term by endangering our planet in the long term. And then these 
corporations and these CEOs expect workers and their families to foot 
the bill.
    We can't protect the economy--and the people who make it work--if 
we don't start by identifying the risks.
    We know far too little about how much climate-related risk is 
sitting on the books of banks and insurance companies.
    It's not a surprise that Wall Street is trying to hide just how 
heavily they've invested in corporate polluters. This lack of 
transparency about the largest U.S. banks' significant investments in 
long-term fossil projects here and abroad hides potential financial 
risks.
    Those are risks that workers and families investing their pensions 
and 401Ks are going to pay the price for.
    We need to know where Wall Street is investing people's hard-earned 
savings. And if it's invested in shrinking industries that threaten 
their jobs and their communities, we need to know about it.
    That means looking at stronger transparency rules, and it means 
looking at whether the tools financial watchdogs already have can help 
us shine a light on these risks.
    While some large banks and other companies have voluntarily 
disclosed some of their investments, not enough of them have, and they 
aren't moving fast enough.
    We needed this years ago.
    Look around--climate-related disasters are already here, and 
they're already grinding local economies to a halt, forcing people out 
of work, and destroying their communities.
    The second polar vortex in a decade to cripple Texas is not far 
behind us, and we're approaching what some are predicting will be an 
above-average hurricane--those are economic risks.
    Persistent drought leaves the Mountain West dealing with wildfires 
that rack up multibillion dollar economic losses year after year, in 
fire seasons that are so constant they've ceased to be seasons--that's 
an economic risk.
    Farmers in the Plains states lost an entire planting season because 
of wet fields or flooding that once would have been shocking, but now 
is all too common--that's an economic risk.
    A three-day downpour flooded more than 100,000 homes in Houston, 
forced hundreds of thousands of people out of their homes, and ground 
commerce to a standstill at one of the three busiest ports in the 
country--with effects like that, it's hard not to think that the only 
way you could fail to see an economic risk, is if you're being paid not 
to see one.
    It's also not enough to just think about the climate risks to 
companies' balance sheets or stock prices--the financial industry, and 
our government, has to take into account the risks to people's 
livelihoods, the communities they live in, the food they eat, and the 
investments they've made for their retirements.
    As we look for opportunities, we need to make sure that American 
industry-steel and aluminum, paper and autos-can access the capital 
they need to reduce or eliminate emissions.
    And when we increase transparency across the financial sector and 
take into account the clear economic costs of climate change, then 
lenders, industry, and workers will be rewarded by making these capital 
investments.
    Today we'll hear from five witnesses who will share their insights 
and expertise on those risks, and the opportunities we all have to 
protect and rebuild our economy. I hope my colleagues will keep an open 
mind.
    Every day that we delay is another missed opportunity to invest in 
new industries and technologies, to make our businesses more 
competitive, and to create jobs in communities that are so often left 
behind.
    And if we don't tell people the truth and take this seriously, we 
know who is going to pay the price.
    It's never CEOs. It's never the corporate boards. It's never 
senators.
    It's going to be the ranchers in North and South Dakota, and the 
line cook in New Orleans, and the kindergartner with asthma in Las 
Vegas, and the steel worker in Cleveland.
    It's their jobs and their savings and their futures on the line. 
And it's our job to be on their side.
                                 ______
                                 
                 PREPARED STATEMENT OF GREGORY GELZINIS
   Associate Director, Economic Policy, Center for American Progress

                             March 18, 2021
    Chairman Brown, Ranking Member Toomey, and Members of the 
Committee: Thank you for the opportunity to testify before the 
Committee on this critical issue. My name is Gregory Gelzinis. I am an 
Associate Director for Economic Policy at the Center for American 
Progress, where I research, and advocate for, policies that would 
create a safer, more stable, and less predatory financial system-one 
that is well-positioned to support long-term economic growth.
    The coronavirus pandemic has proven to be a terrifying reminder 
that our collective livelihoods can be upended by catastrophic 
exogenous shocks, seemingly at a moment's notice. It is incumbent on 
policymakers to use this experience as a catalyst towards addressing 
the impending exogenous shock that will likely disrupt our lives on a 
much greater scale: climate change. The climate crisis has profound 
implications for life and health, as it challenges our very ability to 
sustain a habitable planet. Climate change is also going to have a 
fundamental impact on every sector of our economy, including the sector 
we are here to discuss today: the financial sector.
    The increase in frequency and severity of extreme weather events 
and long-term environmental shifts threatens an array of real assets 
and financial assets. From commercial and residential real estate 
exposures along the coast to agricultural lending in the Midwest, 
climate change could severely impair the value of physical collateral, 
disrupt supply chains, limit economic activity, increase financial 
uncertainty, and strain profitability. These effects would reduce real-
estate and commodity values, lower corporate equity prices, and limit 
the ability of businesses and households to repay debt.
    In addition, the financial system is exposed to transition-related 
risks. If policymakers take the legal and regulatory actions necessary 
to meet emissions and temperature targets, financial institutions whose 
balance sheets don't align with the transition could face significant 
losses. Financial instruments tied to carbon-intensive sectors could 
face a severe repricing as policies restrict and raise the costs of 
emissions. Under certain scenarios, financial institutions could adjust 
to these transition effects abruptly, bursting the carbon bubble and 
creating what former Bank of England Governor Mark Carney has coined a 
``climate Minsky Moment.''
    Climate change does not only present risks to individual 
institutions. It also poses a systemic threat due to the potential 
magnitude of the physical and transition-related risks, the wide array 
of financial institutions and markets exposed to these risks, and the 
speed with which these possibly correlated risks could materialize.
    These risks aren't theoretical. In just the past two years we've 
seen arguably the first climate bankruptcy in PG&E and witnessed energy 
companies, like BP and Total, write down the value of stranded assets, 
as energy price assumptions are re-calibrated.
    The financial sector is finally starting to adjust to these risks 
and recent net-zero commitments from the largest Wall Street banks are 
a welcome development, although such commitments have been light on the 
details and lack near-term plans to meet those long-term goals. But it 
iscritical for regulators to step in and account for these risks in the 
supervision and regulation of the financial system. We can't let Wall 
Street write the rules and rely upon the disproven strategy of self-
regulation, especially as these firms continue to finance the very 
drivers of the climate crisis that put their own balance sheets, as 
well as those of responsible firms, at risk.
    Financial regulators have broad responsibilities under existing law 
to mitigate these climate related risks. Markets regulators have a 
responsibility to protect investors, to promote transparency, and to 
foster healthy markets for securities and derivatives. Prudential 
regulators have a statutory mandate to ensure the safety and soundness 
of financial institutions and to promote the stability of the financial 
system. Climate change clearly falls within these mandates and a 
failure to mitigate climate-related risks would violate the duties 
Congress bestowed upon the financial regulators.
    Thankfully, over the past few months a bipartisan collection of 
U.S. financial regulators have acknowledged that climate change falls 
within their remit. Even though the U.S. is several years behind its 
international peers, recent actions and announcements by the White 
House, Treasury Department, Fed, SEC, CFTC, FHFA, FDIC, and state-level 
regulators signal that momentum is building.
    Like many economic variables, these risks won't be easy to model or 
quantify, given the inherent uncertainty climate change entails. But 
the potential magnitude of the risk demands regulators employ a 
precautionary principle and safeguard the financial system from the 
worst outcomes. Integrating climate change into corporate and financial 
disclosure requirements, fiduciary obligations, stress testing, 
supervision, capital requirements, and systemic risk oversight would 
bolster the resilience of the financial system and position it to serve 
as a source of strength to the economy during the low-carbon 
transition. If regulators fail to act with sufficient speed or refuse 
to use their full panoply of tools, it is imperative for Congress to 
insist that they do so. The stakes are too high.
Climate Change Poses Significant Risks to Financial Institutions and 
        Markets.
    Climate change has fundamental implications for every sector of the 
economy, including the financial sector. Physical risks and transition 
risks are the two primary transmission channels through which climate 
change could impair financial institutions and markets. Physical risks 
stem from the increase in frequency and severity of extreme weather 
events and long-term environmental changes.\1\ Transition risks refer 
to the potential impact that climate policy interventions, clean energy 
technological advancements, and shifts in consumer and investor 
sentiment can have on carbon-intensive financial exposures.
Transition risks
    In order to stabilize global temperatures and mitigate the chances 
of catastrophic climate impacts on the planet, climate policymakers 
must take legal and regulatory steps to drastically decrease greenhouse 
gas (GHG) emissions. The Paris Agreement, signed by the U.S. and 190+ 
other parties in 2015, aims to limit global temperatures to well-below 
2 degrees Celsius above preindustrial levels, and ideally 1.5 degrees 
Celsius.\2\ The Intergovernmental Panel on Climate Change's special 
report in 2018 underscored the imperative to keep warming to 1.5 
degrees Celsius, given the severe consequences associated with even 2 
degrees of warming.\3\ The scientific projections suggest that global 
emissions must reach net-zero by 2050 to plausibly hit the 1.5 degree 
Celsius temperature target.\4\ Achieving these climate goals requires a 
fundamental restructuring of the economy. This low-carbon transition 
isn't several decades away. In many respects, it has already begun. But 
further robust policy changes are required in the near-term to hit 
these targets and avoid catastrophic impacts on communities and the 
economy. Emissions must decline by at least 45 percent from 2010 levels 
by 2030 to remain on track.\5\ The U.S. presently derives roughly 20 
percent of its energy from clean sources, while 80 percent is derived 
from fossil fuels.\6\ President Biden has committed to put the U.S. on 
a path to achieve 100 percent clean energy by 2050.\7\
    If climate policymakers implement the legal and regulatory actions 
necessary to meet these emissions and temperature targets, financial 
institutions whose balance sheets don't align with the transition could 
face significant losses. Financial instruments tied to carbon-intensive 
sectors, e.g., fossil fuel companies, fossil-driven utilities, 
transportation, agriculture, chemical production, and mining and 
metals, could face a severe repricing as policies restrict and raise 
the costs of emissions. Companies engaged in high-carbon activities 
would face increased costs and the potential for fully or partially 
``stranded assets''.\8\ For example, the implementation of rigorous 
energy efficiency standards and other policy interventions that limit 
emissions would severely diminish the value of hydrocarbon reserves. 
Fossil fuel companies would have to write down the value of those 
stranded assets on their balance sheets, impairing their financial 
condition and reducing their ability to meet their financial 
obligations. This dynamic would create losses for their equity 
investors, creditors, and counterparties. Moreover, bank loans to 
fossil fuel companies are often secured by hydrocarbon reserves. 
Transition-related risks can therefore increase the likelihood of the 
loan's default, as well as the loss to the bank if the loan defaults, 
since the collateral would lose value.\9\ This risk is not theoretical, 
as companies are beginning to face the prospects of transition-related 
write-downs. For example, British Petroleum wrote down $17.5 billion in 
assets in June 2020 after lowering its long-term fossil fuel price 
assumptions and Total SE took a $7 billion hit on Canadian oil sands 
assets in July 2020.\10\
    The magnitude of potential financial losses and the prospect for 
broader stability issues in the banking system increase if the 
transition is ``disorderly''. Under such a scenario, policymakers slow-
play the actions necessary to meet emissions and temperature targets, 
before eventually taking more aggressive and rapid actions to make up 
for lost time. Financial losses in the energy sector alone could reach 
$1-4 trillion, depending on the extent to which the transition is 
disorderly.\11\ Taking a broader view of transition-related risks, an 
estimate from IRENA suggests an abrupt and disorderly transition could 
cause upwards of $20 trillion in financial losses.\12\ Technological 
advancements and changes in investor sentiment could also quickly 
trigger many of these dynamics in advance of any actual legal or 
regulatory changes.
    In either an orderly or disorderly scenario, financial institutions 
whose holdings and exposures are not aligned with a low-carbon economy 
could face severe losses, increasing risks to the economy, communities, 
and public funds. Research suggests that the direct and indirect 
exposures to carbon-intensive sectors could propagate stress throughout 
the financial system and disrupt financial stability.\13\ These 
transition-related risks impact credit, market, reputational, 
operational, and liquidity risks.\14\ If financial institutions do not 
adjust to these transition-effects in a timely manner, the 
crystallization of losses could occur abruptly, bursting the carbon 
bubble and creating what former Bank of England Governor Mark Carney 
has coined a ``climate Minsky Moment''.\15\
    A survey of institutional investors suggests the financial system 
is not reflecting these risks in asset prices, as 93 percent responded 
that the implications of climate change had yet to be priced into 
markets.\16\ Research surrounding the projected physical impacts of 
climate change and scenario analyses probing transition-related impacts 
support this view held by institutional investors.\17\. There are 
several reasons that investors have yet to price the impacts of climate 
change into valuations for a range of assets. These include a lack of 
granular, comparable, and reliable corporate disclosure of climate-
related risks; backwards-looking pricing models that are not fit for 
purpose when analyzing forward-looking risks; and the temporal mismatch 
between shortterm corporate thinking and medium-to-long term climate 
risk materialization.\18\
    It's important to note that the low-carbon transition also provides 
incredible opportunities for financial institutions to finance clean 
energy projects and an array of green assets. It's going to take both 
public and private finance to fund the decarbonization of the economy 
and banks and companies that are safeguarded from transition-related 
risks will be best positioned to take advantage of these opportunities.
Physical risks
    The current concentration of greenhouse gases in the atmosphere is 
significantly higher than it has been at any point in the last 800,000 
years.\19\ To maintain stable temperatures, energy coming into the 
planet must be balanced by energy leaving it. Greenhouse gases, 
particularly carbon dioxide, allow energy into the atmosphere, but trap 
energy as it attempts to leave-skewing the balance and increasing 
global temperatures. To this point, the earth has warmed by 1 degree 
Celsius, above pre-industrial levels. As a result, sea-levels are 
rising at an unprecedented rate-driven by melting ice sheets and the 
expansion of seawater as ocean temperatures rise.\20\ Not only are sea-
levels rising, but oceans are becoming significantly more acidic.\21\ 
These environmental changes are driving more frequent and severe 
extreme weather events across the globe. The physical impacts of 
climate change have severe implications for life and health, and the 
overall ability to sustain a habitable planet. And, directly relevant 
to this hearing, they also pose risks to various economic sectors and 
the real and financial assets tied to them.
    Under severe warming scenarios, the physical impacts of climate 
change could drive at least $2 trillion in losses to GDP annually (in 
today's dollars) by 2100, or loosely speaking, the economic equivalent 
of the 2008 financial crisis every 5 years.\22\ Even under more 
moderate warming pathways, macroeconomic impacts could be severe.\23\ 
The real-estate sector faces some of the most acute physical risks. 
Improved flood data, for example, shows that over 14 million properties 
could be at risk from 100-year floods.\24\ The outdated FEMA maps 
estimate that only 8.7 million are at risk.\25\ Zillow mapped flood 
risk data onto its real estate data and estimated that roughly $900 
billion in homes face serious risk from rising sea-levels, and that was 
prior to the publication of the aforementioned research on flood 
risk.\26\ Climate change is already impacting agriculture.\27\ Climate 
change erodes the quality of soil, increases invasive species and crop 
diseases, and leads to more frequent droughts and floods.\28\ These 
physical impacts drive down crop yields and drive commodity price 
volatility. The fishing sector is also impacted by warmer and more 
acidic oceans.\29\ The physical risks of climate change also impact the 
retail and tourism sectors and will have effects on a wide range of 
businesses and industries in affected geographic areas.\30\
    The impact of sea-level rise, warming global temperatures, and more 
frequent and severe floods, hurricanes, droughts, wildfires, and other 
natural disasters could drive up losses for insurance companies, banks, 
private funds, investment companies, pension funds, and other market 
participants invested in exposed assets.\31\ These risks threaten to 
reduce the value of a range of real assets and financial instruments 
tied to commercial and residential real-estate, agricultural lending, 
commercial and industrial lending, municipal and corporate bonds, and 
commodities. Physical risks can impair physical property, disrupt 
supply chains, limit economic activity, increase financial uncertainty, 
and strain profitability, which reduce real-estate and commodity 
values, lower equity prices, and limit the ability of borrowers to 
repay debt.\32\ They can also directly damage and reduce the value of 
collateral that secures credit extended in some of these markets. In 
addition to the credit and market risks posed by the physical effects 
of climate change, they threaten to significantly increase claims for 
an array of property and casualty insurance business lines. Some may 
argue that many of these real assets and financial assets are or could 
be insured, protecting the financial institution or investor from 
losses.
    Insurance companies, however, may, and in some cases have already 
started, to reduce the availability of insurance in certain geographies 
and business lines.\33\ That would leave other financial actors 
increasingly exposed to physical-risk losses. Even if insurance 
companies stay in these impacted markets or geographies, the difficulty 
in modeling the non-linear effects of climate change could leave 
insurance companies themselves overly exposed to physical risks.\34\ 
Similarly, given the non-linear nature of the risks, the credit default 
swap and debt markets will continue to have difficulty accurately 
pricing these risks, which can impact single issuers, geographic 
regions, or whole industries. Rapid re-pricings of debt securities may 
also impact equity and options holdings of the underlying issuers. Put 
simply, financial instruments tied to the fates of companies and 
municipalities, which may be held by public or private fund investors, 
pensions, and even individuals, may suffer significant losses.
    These risks are not theoretical, and they are not far off in the 
distance. They are already here. Severe weather events have caused $106 
billion in damage a year on average over the past 5 years, 
significantly higher than the 1980-2019 average of $43.9 billion.\35\ 
Based on the projected intensification of these events, they could 
trigger trillions of dollars in losses for financial institutions and 
investors exposed to these assets in the coming years and decades.\36\ 
Many have labeled the wild-fire driven bankruptcy of the utility 
company PG&E in 2019 as the first climate-related bankruptcy, initially 
wiping out around $20 billion in market capitalization (roughly 85 
percent of the late 2018 level).\37\ Even if policymakers are 
successful in limiting warming to 1.5 degrees Celsius above pre-
industrial levels, extreme weather events will be substantially more 
severe and frequent than they are today and long-term environmental 
shifts will continue to progress. Today, the world has warmed about 1 
degree Celsius above pre-industrial levels and the destructive impacts 
are clear. Another 50 percent increase in warming will meaningfully 
exacerbate the physical impacts of climate change-and that's under the 
best-case scenario. It's worth underscoring that low- and moderate-
income communities and communities of color are likely to be the 
hardest hit by physical risks and the least able to financially bear 
the resulting costs. Meanwhile, it is these very same communities that 
disproportionately suffer the consequences of the industrial pollution 
produced by the very drivers of the climate crisis.\38\
Financial regulators have a statutory responsibility to mitigate 
        climate-related risks to financial institutions, investors, and 
        the stability of the financial system.
    A few years ago, it was a common refrain among some financial 
regulators that climate change fell outside their core mandates. To be 
clear, financial regulators are not being asked to set climate policy. 
That is the responsibility of Congress and other executive agencies. 
Financial regulators are simply being asked to do the jobs Congress 
assigned--to protect the financial system and broader economy from 
damaging financial risks.
    Thankfully, many financial regulators--both Democrats and several 
Republicans appointed by President Trump-now acknowledge that climate-
related financial risks fall squarely within their statutory 
mandates.\39\ It is rapidly becoming a broadly bipartisan issue. But 
the original refrain, and the idea that efforts to get financial 
regulators to focus on climate-related risks are ``the left'' pushing a 
social engineering project, still appears in some corners.\40\ It is 
therefore worth briefly clarifying how the aforementioned climate-
related financial risks intersect with the mandates and authorities of 
various regulators. The specific policies that financial regulators can 
and should implement to mitigate climate-related financial risks are 
discussed in greater detail in Section IV of this testimony.
Markets regulators
    The Federal securities laws were created to ensure that investors 
and the public have essential information about companies so as to 
promote the efficient allocation of capital and protect investors. As 
Congress explained when adopting the Securities Act of 1933,

        Whatever may be the full catalogue of the forces that brought 
        to pass the present depression, not least among these has been 
        this wanton misdirection of the capital resources of the Nation 
        . The bill closes the channels of such commerce to security 
        issuers unless and until a full disclosure of the character of 
        such securities hasbeen made.\41\

    The Securities and Exchange Commission (SEC) was established in 
1934 to promote the effective implementation and oversight of the new 
rules. Its mission is to protect investors; maintain fair, orderly, and 
efficient markets; and facilitate capital formation.
    Information about companies and their risks is essential to 
facilitating the efficient allocation of capital and protecting 
investors. The climate-related financial risks outlined above intersect 
with that mission in several important ways. The Commission has broad 
authority to require disclosures by issuers to ensure that investors 
and the broader public have the information necessary to accomplish 
those statutory goals.\42\ Over the years, corporate issuers and their 
allies have sought to constrict the Commission's disclosure framework 
to a narrowly defined ``materiality'' framework that is essentially 
tied to whatever the company itself (or its management) believes to 
have a significant impact on the company's finances. But the SEC's 
statutory authority is not limited to that constricted view.\43\ 
Rather, the disclosure obligation must center the needs of investors 
and the public interest-as its statutory authorization makes clear. 
Corporations should not be deciding what information investors or the 
public require to make prudent capital allocation decisions or protect 
the public interest.\44\ The physical and transition risks associated 
with climate change have implications for the ongoing operations of 
companies in every sector of the economy, both positive and negative. 
Understanding a company's direct and indirect greenhouse gas emissions, 
energy consumption, fixed-asset and supply chain exposure to extreme 
weather disruptions, and other climate-related factors are necessary 
for investors to make prudent capital allocation decisions. Investors 
have made it very clear that they want this information. A lack of 
transparency could drag on economic growth with overinvestment in 
certain sectors or companies, and underinvestment in others.
    Whether and to what extent the SEC requires comprehensive, 
reliable, and comparable information from issuers of securities will 
have profound impacts on whether and how companies and investors are 
efficiently allocating capital and assessing risks. For example, much 
of the corporate debt securities markets are currently exempt from SEC 
disclosure obligations. If a large fossil fuel company sells billions 
of dollars in debt securities that are not due for 15 years or more, 
what are the climate-related risks of those securities?
    The SEC also oversees registered investment advisers and investment 
companies. A broad range of investors are looking for fund products 
that both limit their climate-related exposures and direct investment 
towards green climate solutions.\45\ The SEC has a statutory 
responsibility to ensure that funds holding themselves out as ``green'' 
are not misleading investors, but these investors (as well as banks, 
insurance companies, pension funds, and others) can only manage their 
portfolios to meet these ``green'' expectations if they are getting 
comprehensive, reliable, and comparable information from the companies 
in which they invest.\46\ To go back to the example above, how can an 
investment adviser assess the risks to its funds holding of a fossil 
fuel company's debt securities if the party best positioned to identify 
and disclose them hasn't done so?
    Furthermore, as climate risk impacts the price outlook for various 
investments, entities with a fiduciary obligation overseen by the SEC 
must increasingly take such risks into account when providing 
investment advice to meet those obligations, regardless of their 
investment strategies.\47\ Put simply, fiduciaries cannot ignore these 
risks. Climate change impacts other institutions under the SEC's 
jurisdiction, including broker-dealers, credit rating agencies, and 
auditing and accounting firms.\48\ Broker-dealers are exposed to market 
risk posed by transition and physical risks, credit rating agencies 
will need to update their rating methodologies to ensure climate 
related risks to fixed-income issuances are factored in, and auditing 
and accounting firms will be increasingly essential to ensure that 
climate risks are accurately accounted for and company disclosures are 
reliable. If the SEC fails to integrate climate-related risks into its 
core regulatory framework, it will fall short of its statutory mission. 
Investors will be exposed to risks that were not sufficiently disclosed 
to them, capital will be inefficiently allocated, our markets will be 
anything but orderly, and it will serve as a drag on capital formation 
due to a loss of investor confidence in the resilience and transparency 
of markets.
    The SEC's recent announcement under Acting Chair Allison Herren Lee 
that the agency's Division of Examinations team is focusing on 
companies' disclosures and compliance with the agency's 2010 climate 
risk-related guidance\49\ and investment advisers' claims and practices 
regarding sustainable investing is a great step towards ensuring 
accountability under the existing rules. So, too, was the announcement 
of the SEC's creation of a Taskforce on Climate and ESG within the 
Division of Enforcement. However, the SEC's expectations for companies, 
investment advisers, broker-dealers and other essential market 
participants need to be modernized to reflect the magnitude of the 
risks and impacts of climate change on seemingly every aspect of our 
economy.
    The Commodity Futures Trading Commission (CFTC) is the primary 
derivatives regulator in the U.S. and is responsible for promoting the 
integrity, resilience, and vibrancy of derivatives markets. The agency 
has authority to impose disclosure requirements, margin and capital 
rules, risk management standards, and other safeguards on the firms and 
products under its jurisdiction.\50\ The physical and transition risks 
caused by climate change could impact the value and volatility of 
commodity prices and drive losses at the market participants exposed to 
these assets, including through derivatives. For example, chronic 
droughts and an increase in crop diseases in the Midwest could impact 
corn prices and rising temperatures in the Mississippi Delta could 
impact rice yields. Moreover, the clean energy transition necessary to 
stabilize global temperatures will have a considerable impact on fossil 
fuels and metals commodities. Increased risk and volatility in these 
and other commodities markets could impact futures commission 
merchants, central counterparties, and other market participants. The 
CFTC also oversees swaps dealers and major swaps participants. Credit 
default swaps on a basket of energy companies or a commercial mortgage-
backed security index, for example, could be affected by climate-
related risks. The 2008 financial crisis showed the costs of an 
underregulated derivatives market, and it is imperative for the CFTC to 
appropriately account for climate-related risks in its regulatory and 
supervisory framework.
Prudential regulators and the Financial Stability Oversight Council
    The prudential banking regulators, the Federal Reserve Board (Fed), 
Federal Deposit Insurance Corporation (FDIC), and Office of the 
Comptroller of the Currency (OCC) have a statutory responsibility to 
ensure the safety and soundness of the banking organizations under 
their respective jurisdictions and to promote the overall stability of 
the banking system. The banking regulators play a critical function in 
our economy. Reducing the chances and severity of banking crises, 
protecting depositors and the public funds that stand behind insured 
deposits, and ensuring our banking system is supporting productive 
economic investment instead of speculation all help to orient our 
economy towards long-term, sustainable, and equitable growth. When 
these regulators fall short, we've all-too-recently seen the resulting 
economic devastation that bank failures, fire-sales, runs, and a 
contraction of credit can have on businesses and households across the 
country. Congress has afforded banking regulators broad writs of 
authority to execute this critical mission in several statutes, 
including the Federal Deposit Insurance Act, the Bank Holding Company 
Act, the International Lending Supervision Act, and most recently, the 
Dodd-Frank Wall Street Reform and Consumer Protection Act, among 
others.\51\ Through these statutes, regulators have significant 
authority to use supervisory tools, capital and liquidity requirements, 
stress testing, recovery and resolution planning, risk management 
requirements, and other prudential tools that they deem appropriate to 
address any risks to individual institutions--microprudential risks--as 
well as risks to the overall functioning of the banking system--
macroprudential risks.
    Climate change poses microprudential risks to banks, including 
credit, market, liquidity, reputational, and operational risks. All 
banks, large and small, receive special public privileges due to the 
inherent fragilities of the banking business model and the key role 
banks play in providing credit, offering payment services, and most 
importantly, issuing deposits. These privileges include deposit 
insurance and access to the Fed's discount window, but also come with a 
regulatory and supervisory framework to mitigate moral hazard and the 
externalities failures can impose. Even though the failure of a $10 
billion bank won't create a systemic crisis, regulators still have a 
responsibility to ensure the safety and soundness of the bank, since it 
still receives these public privileges, and its failure could still 
have a harmful impact on the local or regional economy. Individual 
banks are exposed to varying degrees of climate-related risk depending 
on the types of assets they hold and the geographic location of those 
assets. For example, a bank with a high concentration of coastal 
commercial real-estate exposure could face severe losses from rising 
sea-levels. A bank that finances agricultural loans could face losses 
if droughts, floods, and pests decrease the crop yield for a farmer who 
then can't meet her financial obligations. Moreover, a bank in the oil 
patch that focuses on reserve-based lending to oil and gas exploration 
and production companies could face losses if hydrocarbon reserves are 
devalued as a result of the clean energy transition, increasing both 
the likelihood of default on the loan and the loss to the bank if the 
loan does, in fact, default.
    The prudential regulators not only have a responsibility to 
mitigate climate-related risks for individual institutions. They must 
also address the macroprudential risks created by climate change-that 
is, the risks to the overall functioning of the banking system and 
broader financial sector. As Federal Reserve Board Governor Lael 
Brainard has noted, ``Climate change could pose important risks to 
financial stability. That is true for both physical and transition 
risks.''\52\ Climate change is a systemic threat due to the potential 
magnitude of the physical and transitionrelated risks it poses, the 
wide array of financial institutions and markets exposed to these 
risks, and the speed with which these possibly correlated risks could 
materialize.\53\ Climate-related shocks could impair the normal 
functioning of the financial system and inflict damage on the broader 
economy. A physical or transition shock could cause severe losses at a 
systemically important financial institution or correlated losses 
across a string of financial institutions, leading to fire sales of 
impaired assets, creditor runs from distressed institutions, and 
second-order counterparty losses and contagion at institutions that may 
not have been directly exposed to the initial shock.\54\ These first- 
and second-order effects could create vicious feedback loops, undermine 
confidence in the financial system, and ultimately trigger a credit 
contraction and a broad increase in the cost of financial 
intermediation.
    SEC Acting Chair Allison Herren Lee has cautioned that climate-
driven financial stability disruptions ``can also spread in ways that 
are less predictable because climate risk is unique in terms of its 
scope, breadth, and complexity.''\55\ In a particularly troubling 
financial stability scenario, a physical shock could trigger a near-
simultaneous transition shock. After delaying robust and orderly 
decarbonization, a brutal string of natural disasters could spur 
policymakers to take aggressive and disorderly steps to stabilize 
global temperatures. In short, climate-related shocks could be 
immediately amplified by and transmitted throughout the financial 
system, disrupting the normal functioning of the system and leading to 
spillover effects on the real economy.\56\ Another macroprudential 
concern short of a systemic crisis is that physical and transition 
risk-related losses could chronically erode the resilience of financial 
institutions over time and leave the system vulnerable to other shocks.
    In addition to the macroprudential responsibilities and authorities 
afforded to the prudential banking regulators, the Dodd-Frank Act 
created a new financial stability watchdog-the Financial Stability 
Oversight Council (FSOC). Although the United States is notable for 
having many financial regulatory agencies, before the 2008 financial 
crisis, no one regulator or regulatory body was responsible for looking 
out across the financial system and addressing systemic risks. 
Financial regulators focused on their respective jurisdictions, while 
significant risks built up across jurisdictions and outside of any one 
regulator's purview. Risky financial activities and products sprouted 
in the cracks of the financial regulatory infrastructure as regulatory 
arbitrage, intentionally exploiting its fragmentation. The FSOC was 
structured to mitigate some of these regulatory design flaws. It is 
chaired by the secretary of the U.S. Department of the Treasury and 
brings together the heads of all eight federal financial 
regulators,\57\ and a voting member with insurance expertise, around 
one table.\58\ The FSOC's goal is to improve coordination across 
agencies and tackle emerging financial sector risks and vulnerabilities 
before they trigger or amplify another financial crisis. Climate change 
has implications for every part of the financial system and, in turn, 
every financial regulator. It is the exact type of cross-cutting risk 
that the FSOC was designed to address. The FSOC can use its research 
and coordinating functions to drive better climate-related risk 
analysis, monitoring tools, and risk-mitigating policies at primary 
regulators. When necessary, it can also use its powerful statutory 
tools to directly address certain climate-related risks and push 
primary regulators to act.
    It's important to note that the banking regulators and FSOC are not 
supposed to focus solely on the microprudential or macroprudential 
risks to which financial institutions are exposed. They also have a 
responsibility to mitigate risks created or exacerbated by financial 
institutions that could then drive losses elsewhere in the financial 
system. For example, Section 165 of the Dodd-Frank Act directs bank 
regulators to develop macroprudential regulations to ``prevent or 
mitigate risks to the financial stability of the United States that 
could arise from the material financial distress or failure, or ongoing 
activities, of large, interconnected financial institutions . . . '' 
(emphasis added).\59\ That principle is embedded throughout the Dodd-
Frank Act.\60\ In the context of climate change, prudential regulators 
and the FSOC have a statutory mandate to mitigate climate-related risks 
created or exacerbated by financial institutions' ongoing activities. 
Notably, financial institutions that are major financiers of carbon-
intensive activities are facilitating increased GHG emissions and 
intensifying climate change. Exacerbating the climate crisis will 
increase both the physical and transition risks of climate change and 
inflict larger losses on the financial system. With respect to physical 
risks, higher GHG emissions lead to higher global temperatures, which 
in turn cause more frequent and severe extreme weather events and 
damaging environmental changes.\61\ The more significant the physical 
effects of climate change, the more likely and severe the financial 
system's associated losses will be. Furthermore, increased emissions 
today drive up projected warming pathways and increase the likelihood 
that a rapid and disruptive transition is required to stabilize global 
temperatures.\62\
Other Regulators
    This testimony focuses primarily on markets regulators, prudential 
banking regulators, and the FSOC, but climate change has implications 
for other state and federal regulators as well. Credit unions, which 
receive a distinct charter and are regulated by the National Credit 
Union Administration (NCUA), face similar microprudential risks as 
banks. The NCUA, likewise, has similar tools to promote the safety and 
soundness of credit unions. As mentioned earlier, the physical effects 
of climate change-particularly sea-level rise-poses significant risks 
to the commercial and residential real-estate markets. The Government 
Sponsored Enterprises (GSEs), Fannie Mae, Freddie Mac, and the Federal 
Home Loan Banks, have significant exposure to these markets. In fact, 
there is increasing evidence that banks are off-loading substantial 
flood risk to Fannie and Freddie.\63\ The Federal Housing Finance 
Agency (FHFA) is the prudential regulator for the GSEs and has broad 
authority to ensure their ongoing safety and soundness. Similarly, the 
Public Company Accounting Oversight Board (PCAOB), the Municipal 
Securities Rulemaking Board (MSRB), and the Financial Industry 
Regulatory Authority (FINRA) each have important roles to play. For 
example, to the extent that the SEC requires companies to make climate 
related estimates and disclosures, the PCAOB will have an essential 
role in ensuring that those estimates and disclosures are comparable 
and reliable. The Consumer Financial Protection Bureau could help 
consumers hold banks accountable on issues of sustainability, 
effectively empowering them to ``vote with their deposits'' by making 
it easier to seamlessly switch their bank accounts, something that is 
surprisingly challenging to do today.\64\
    Finally, the insurance sector is arguably the most acutely exposed 
to the physical risks of climate change, since the core business model 
for property and casualty insurers involves guaranteeing the value of 
physical assets. Insurers' investments are also exposed to physical and 
transitionrelated risks. Insurance is primarily regulated at the state-
level, meaning state insurance regulators have a critical role to play 
in mitigating these risks. But the FSOC and Federal Insurance Office 
(FIO) must closely monitor such risks and use their own tools to 
address them, when necessary.
The U.S. is behind its international peers in addressing climate-
        related financial risks, but there are recent signs of 
        progress.
    International regulators have acknowledged the severity of climate-
related risks and the need for financial regulators to act urgently to 
mitigate such risks. The Network for Greening the Financial System 
(NGFS) was established in December 2017 by eight central banks as a 
coordinating body for those central banks and supervisors committed to 
tackling climate-related financial risks. Since then, the NGFS 
membership has expanded to 83 members and 13 observers, representing 
about 75 percent of global GDP and the vast majority of the world's 
systemically important financial institutions.\65\ The NGFS has put out 
multiple research reports, sample supervisory guidance, model stress 
testing scenarios, and more over the past several years.\66\ Many NGFS 
members have begun, in turn, to adapt their core regulatory and 
supervisory frameworks accordingly. The Basel Committee on Banking 
Supervision published the results of its climate-related stock take of 
how member jurisdictions are approaching climate-related risks.\67\ Of 
the 27 jurisdictions surveyed, 24 had conducted climate-related 
research, 23 had raised the issue directly with banks, and 6 had issued 
supervisory guidance (with 5 more in the process of doing so).\68\ Some 
jurisdictions have advanced mandatory climate disclosure frameworks and 
have implemented, or are in the process of implementing, climate-
related stress testing and scenario analysis regimes.\69\ In many 
jurisdictions, this activity has been driven by regulators under 
existing authority, while legislative bodies in certain jurisdictions 
have set comprehensive frameworks.\70\
    The U.S. has made little progress on addressing climate-related 
risks, while U.S. financial institutions are lagging their 
international counterparts in curbing climate-risky activities. The 
tide is shifting, however, and recent actions are cause for optimism. 
In September 2020, the CFTC Climate-Related Market Risk Subcommittee, 
established by Commissioner Rostin Behnam, published the first 
official-sector commissioned report in the U.S. on climate-related 
financial risks.\71\ In November 2020, the Fed included climate-related 
risks in both its Supervision and Regulation Report and Financial 
Stability Report, before ultimately joining the NGFS in December.\72\ 
This was welcome news, as Governor Lael Brainard has been talking about 
the need for the Fed to focus on climate change for years.\73\ 
Additionally, the Fed recently created a Supervision Climate Committee 
to evaluate and mitigate the microprudential risks posed by climate 
change.\74\ SEC Acting Chair Allison Herren Lee has taken steps over 
the past two months to better integrate climate-related risk in the 
Commission's disclosure, examination, and enforcement functions.\75\ 
FDIC Chair Jelena McWilliams announced that focusing on climate 
change's impact on the financial sector was recently added to the 
agency's performance goals for the first time.\76\ FHFA Director Mark 
Calabria recently issued a fairly comprehensive public request for 
information regarding how the agency should integrate climate-related 
risks into its core functions.\77\
    The Biden administration has also signaled that addressing climate-
related financial risks would be a key priority within the all-of-
government approach to the climate crisis. A recent executive order 
directed the Treasury Secretary to ensure the U.S. was present at 
international fora working on climate-related financial risks and the 
executive order reinforced the Paris Agreement's goal to align capital 
flows with a 1.5-degree Celsius warming pathway.\78\ Secretary Yellen 
has repeatedly emphasized the importance of this issue for multiple 
Treasury core functions, including the Secretary's role as Chair of the 
FSOC. She has even committed to establishing a ``climate hub'' at the 
Department.\79\ Certain state-level regulators have also started to 
make real progress on this issue. The New York Department of Financial 
Services, in particular, has taken some nation-leading steps on this 
front.\80\ The California Department of Insurance, under Dave Jones' 
leadership, also made notable progress during his tenure.\81\
    The U.S. is behind our international counterparts. The building 
momentum, though, suggests the next few years could be a ``leapfrog 
moment'' for our country, as Sarah Bloom Raskin, former Treasury Deputy 
Secretary and a global leader on climate-related financial issues, has 
characterized the present opportunity for action.\82\
Financial regulators have the tools to advance a robust policy agenda 
        to mitigate climate-related financial risks.
    The U.S. is moving beyond merely the identification and evaluation 
phase of this effort, but not fast enough. A bipartisan set of 
regulators acknowledge that climate change poses risks to the financial 
system and, therefore, falls within their statutory remit. We cannot, 
however, fall victim to the calls for self-regulation of these risks. 
It is welcome news that large U.S. banks are making net-zero 
commitments and that more companies are utilizing myriad voluntary 
disclosure frameworks, but many of these commitments do not set clear 
short-term goals and rely too heavily on promises of future emission 
offsets. In any event, these developments do not absolve regulators of 
their responsibility to ensure that firms are resilient to these risks 
and that investors have the information they need to appropriately 
allocate capital. The U.S. has tried selfregulation in the past, and 
that hands-off approach has proven catastrophic for workers, small 
businesses, and communities across the country. Private financial 
institutions do not have sufficient incentives to voluntarily self-
insure against climate-related risks, especially tail risks. It is 
therefore critical for regulators to step in and ensure these risks are 
accounted for in regulatory and supervisory frameworks. Moreover, the 
absence of climate-related safeguards provides a hidden subsidy to the 
banks exposed to, and exacerbating, these risks. Banks that are not 
creating or exposed to these risks bear those costs.
    Regulators have the tools to mitigate these risks.\83\ The question 
now is how urgently will regulators move to mitigate these risks and 
what specific safeguards will they employ? If regulators pursue a 
robust climate finance agenda, the U.S. financial system will be 
wellpositioned to handle future climate shocks and to take advantage of 
the significant opportunities that the transition to a low-carbon 
economy presents. Meanwhile, the public will be spared the high costs 
of future bailouts and will benefit from a stable financial system.
    One of the most important lessons policymakers should have learned 
from the 2008 financial crisis is the importance of deploying a 
precautionary principle when regulating the financial system. As 
Professor Hilary Allen describes it, ``This principle is essentially a 
more sophisticated version of the old adage, `better safe than sorry,' 
counseling regulators to err on the side of regulating an activity when 
the outcome of that activity is uncertain, but potentially irreversible 
and catastrophic.''\84\ In the run-up to the 2008 crisis, many 
policymakers assumed financial crises were a thing of the past and did 
not cast a skeptical eye towards the development of new complex 
financial products and systemic interconnections.\85\ A laissez-faire 
deregulatory approach, the opposite of the precautionary principle, 
dominated the three decades leading up to the crisis and set the stage 
for the resulting catastrophe. Regulators must have humility about 
their ability to predict the precise causes and complex effects of 
financial crises, which are high impact and low probability events that 
carry substantial inherent uncertainty. Regulators must act to ensure 
the financial system is resilient to extreme, but plausible, tail risk 
scenarios. The severe and lasting economic and social damage wrought by 
instability in the financial system warrants this type of precautionary 
approach to regulation-one that favors proactive and robust safeguards 
in the face of uncertain, but potentially catastrophic, risks.
    Certainty regarding the near-term private costs of regulation and 
uncertainty regarding the precise value of social benefits from such 
regulation-which nevertheless are likely to be great in magnitude-
should not unduly hamstring regulators. Climate-related financial risks 
are a special case that warrant a particularly proactive approach.\86\ 
Climate change is itself a high impact and high probability phenomenon. 
It will certainly have significant negative effects on the planet, 
economy, and financial system. There is no doubt about the likelihood 
of climate change and no doubt about the general magnitude of its 
damaging impacts under various warming scenarios. It is also clear that 
the transition to a low-carbon economy, which is necessary to stabilize 
global temperatures, is going to impact financial institutions and 
markets. There is significant uncertainty, however, regarding the 
timeline of climate-related financial stability risks, the precise 
magnitude of the economic value at risk, and the exact manifestation of 
those risks on a range of financial assets, markets, and institutions. 
The answers to many of these questions hinge on the level of emissions 
going forward and the resulting warming pathway, as well as the future 
actions taken by policymakers, technological advancements, and shifts 
in market sentiment. The uncertainty is fueled by difficulties modeling 
climate change and its impacts, including its non-linear nature, the 
existence of tipping points, and the interactions with complex 
environmental systems.\87\ It is clear, however, that climate-related 
risks could have a catastrophic impact on financial institutions and 
markets, and ultimately disrupt financial stability.
    This policy effort will be an iterative process. Given the urgency 
of the issue and the magnitude of the risk, it is important for 
regulators to not let the perfect be the enemy of the good and to act 
with urgency. As Fed Governor Lael Brainard recently stated, ``Despite 
the challenges, it will be critical to make progress, even if initially 
imperfect, in order to ensure that financial institutions are resilient 
to climate-related financial risks and well-positioned for the 
opportunities associated with the transition to a more sustainable 
economy.''\88\ Regulators should advance a comprehensive and vigorous 
agenda to mitigate climate-related financial risks-an agenda that 
embodies the precautionary principle.
Markets regulators\89\
    Disclosure
    The SEC should establish a mandatory climate risk disclosure 
framework.\90\ Investors need reliable, consistent, and comparable data 
on climate-related risks. The myriad voluntary disclosure frameworks 
that have developed over the past several years have helped get the 
ball rolling on this important issue, but only a mandatory standardized 
regime can provide the reliable, consistent, and comparable information 
necessary for investors to make prudent decisions when they allocate 
capital. The disclosures should include both specific line-item 
requirements and additions to the narrative-based disclosures in the 
management discussion and analysis, such as those called for by the 
Task Force on Climate-related Financial Disclosures.\91\
    The line-item disclosure should at least include clear metrics 
regarding the exposure of corporate assets, facilities, supply chains, 
services, and products to water stress, natural disasters and 
environmental shifts, water insecurity, heat stress, and additional 
physical risk-related factors.\92\ Companies should also be required to 
disclose metrics regarding their energy consumption, scope 1, 2, and 3 
emissions, and their transition-related emissions targets. For 
financial institutions, the Commission should require disclosure of the 
emissions financed by the firm.\93\ Moreover, the management discussion 
and analysis should include transition plans and the board and 
management strategy for addressing climate-related risks. This is not a 
comprehensive list of all of the necessary elements of a corporate 
climate risk disclosure framework, but the aforementioned metrics 
should be core components. Additionally, climate disclosures should not 
be considered in a vacuum. Investors have been asking for a broad array 
of ESG information, much of which intersects with how companies are 
thinking about their climate risk. SEC Acting Chair Lee recently spoke 
to the interconnected nature of ESG factors, saying, ``We know climate 
presents heightened risks for marginalized communities, linking it to 
racial justice concerns.''\94\ Lee also pointed out the risk to 
investors from companies that make public commitments regarding carbon 
neutral policies, but secretly donate to political candidates with 
anti-climate justice records. It's important that climate risk 
disclosure be part of a comprehensive ESG disclosure regime.
    Restoring the Application of Securities Laws
    The SEC must also ensure that this framework applies to all large 
companies and offerings. Over the past several decades, and 
particularly since the passage of the Jumpstart Our Business Startups 
(JOBS) Act, ever larger companies and offerings are proliferating 
outside of the SEC's disclosure and accountability framework. That 
should be reversed.\95\
    Efforts to promote the disclosure and accountability of the public 
markets could include limiting the application of Rule 506 and 
requiring additional disclosure requirements on issuers making use of 
the exemption, as well as eliminating or modifying Rule 144A.\96\ 
Without restoring the primacy of the public capital markets, the SEC's 
efforts to promote transparency will be severely undermined-and climate 
risks will continue to be insufficiently identified, assessed, and 
addressed.
    Restoring Rights
    For years, long term investors have engaged with companies and 
their management teams to promote better identification, assessment, 
and management of risks, including climate risks. Oftentimes, investors 
have used shareholder proposals and their powers to vote to hold 
companies and their executives accountable. Unfortunately, these tools 
have been undermined in recent years. The SEC should promote investor 
engagement, including through easing submissions for shareholder 
proposals and expanding the ability of investors to shape corporate 
action, such as by reducing dual class share structures and adopting 
universal proxy ballots. Investors can and must be empowered to protect 
their interest in corporate sustainability.
    Fiduciary Requirements
    The SEC and Department of Labor should require investment 
fiduciaries to develop and implement policies and procedures that 
clearly outline how the adviser identifies, evaluates, and addresses 
climate-related risks and opportunities. SEC Acting Chair Allison 
Herren Lee has suggested the Commission could pursue this type of 
requirement under existing law and that there is precedent for 
requiring ``policies and procedures around a specific topic of 
particular importance.''\97\ This type of sustainable investment policy 
would help provide clarity to investors as to how fiduciaries are 
integrating climate-related considerations into the advice they are 
providing, without dictating outcomes that fiduciaries would be 
required to follow.\98\ Relatedly, the SEC could require investment 
advisers and broker dealers to ascertain the climate-related 
preferences of investors and factor those preferences into their 
investment decisions.
    Additional tools
    Capital markets regulators have an array of additional tools that 
could be used to mitigate climate-related risks to the firms and 
markets under their jurisdiction.\99\ The SEC should (i) require credit 
rating agencies to disclose how they are integrating climate-related 
risk into their rating methodologies and ensure they are applying those 
models consistently; (ii) enforce existing accounting standards with 
respect to climate-related risks and expand those standards to more 
fully integrate the risks; (iii) ensure that auditors have the skills 
and knowledge necessary to audit for compliance with accounting 
standards as they relate to climate risks; and (iv) establish and 
enforce a clear taxonomy that promotes standardized labeling for 
``green'' or ``ESG'' funds and securities to prevent greenwashing.\100\ 
In addition, the CFTC should adapt its margin and capital requirements 
to account for climate-related risks to specific entities and markets 
under its jurisdiction.\101\
Prudential regulators
    Stress Testing
    The Federal Reserve should establish climate-related stress tests 
for the largest banks in the country.\102\ The stress tests would probe 
how bank balance sheets would be impacted by hypothetical severely 
adverse climate scenarios over the next 15-30 years. The time horizon 
of the climate-related stress tests should be much longer than the 
nine-quarter horizon for the annual macro stress tests to allow 
regulators to explore how the worst effects of climate change could 
impact bank balance sheets. The scenarios should include both physical 
and transition risks. Banks should then be required to submit detailed 
remediation plans that outline how they plan to adjust their balance 
sheets and financing activities over time to mitigate their exposure to 
these risks. Unlike the annual macroeconomic bank stress tests, these 
tests should not quantitatively set capital requirements. The inherent 
difficulties in projecting losses over such a lengthy time horizon make 
these stress tests ill-suited for setting bank-by-bank capital 
requirements immediately.
    Even though the quantitative results of the tests shouldn't 
directly set capital requirements, it is critical for the stress tests 
to have teeth and not become a box checking exercise of little value. 
Regulators should therefore include a qualitative objection component 
in the climate-related stress tests. If the remediation plans are 
inadequate in scale or granularity, or if climate change is 
insufficiently integrated into banks' internal controls, governance, 
risk management, or capital planning processes, the Fed should invoke 
the qualitative objection and restrict banks' planned capital 
distributions today. The climate-related stress tests would provide 
transparency regarding banks' climate-risk exposure, force banks to 
embed climate risk into their core business functions and require them 
to provide regulators with actionable plans to adjust their balance 
sheets over time to limit climate-related risks.
    Conducting several iterations of the climate-specific stress tests 
should improve regulators' understanding of climate-related variables, 
scenario design, and modeling. Ultimately, near-term climate-related 
variables and shocks should be introduced into the severely adverse 
scenario of the nine-quarter annual macroeconomic stress tests, the 
Comprehensive Capital Analysis and Review (CCAR). These annual stress 
tests directly feed into banks' capital requirements, as regulators use 
both static and dynamic tools to ensure capital adequacy.\103\ Adding 
climate variables and shocks to these tests would help integrate 
climate considerations into the bank capital framework.
    Banks have pushed back against the creation of climate-related 
stress tests.\104\ They have argued that there is significant 
uncertainty around climate-related shocks and their effects, and that 
they'd be tough to model. It is true that there is substantial inherent 
uncertainty around climate-related risks and potential warming and 
transition pathways. But stress tests are not designed to predict the 
future. They are used to test bank balance sheets against extreme, but 
plausible, scenarios. That's a threshold the Fed should be able to 
meet. There are certainly data, modeling, and scenario decisions that 
the Fed will have to weigh carefully. Those challenges are by no means 
insurmountable given the purpose and role of stress testing. Moreover, 
banks have lamented the long time horizon of the scenarios as it 
relates to assumptions regarding bank balance sheets. It is certainly 
true that a bank's balance sheet could look very different in 2045 than 
it does in 2021. Stressing a bank's 2021 balance sheet against longer-
term risks, however, demonstrates just how significantly a bank may 
have to adjust its balance sheet over time to avoid catastrophic 
climate-related losses. The Fed could then ensure banks are, in fact, 
adjusting their balance sheets over time to avoid these long-term 
risks. It's also important to note that while the most severe climate-
related risks may take decades to materialize, there are potential 
risks in the more immediate future-particularly with respect to 
transition risks. In order to hit 2050 emissions and warming targets, 
rigorous action is required in the near-term. Those legal and 
regulatory developments, or technological advancements and shifts in 
investor sentiment, could crystallize transition-related losses in the 
short-term and should be included in CCAR at some point soon.
    The arguments banks are making against climate-related stress tests 
rhyme with the arguments they deployed against the initial stress tests 
in 2009, the Supervisory Capital Assessment Program, and the annual 
macroeconomic tests that were developed in the wake of the crisis, 
CCAR.\105\ For 12 years banks have fought tooth and nail with the Fed 
over what constitutes appropriate or realistic scenarios, models, and 
assumptions. One particular example is instructive. In CCAR, the Fed 
included an assumption that bank balance sheets would grow during the 
stress testing time horizon. This was a prudent assumption, since 
regulators want banks to be capitalized enough to serve as a source of 
strength during a downturn and historical evidence suggested that there 
would be pressure on bank balance sheets to expand as businesses and 
households sought liquidity. While it may be prudent from a 
microprudential standpoint to assume banks could keep a static balance 
sheet or shrink to conserve capital during a stress period, that would 
lead to a severe contraction in credit if a range of banks all took 
that approach. After years of pressure from banks, the Fed relented and 
watered down the balance sheet growth assumption and changed it to 
assume a flat balance sheet.\106\ Then, in early 2020, the global 
financial system experienced a real-life stress test due to the COVID-
19 shock and bank balance sheets grew significantly.\107\ Banks were 
not pushing the Fed to adopt a flat balance sheet because it was more 
realistic or grounded in historical evidence. They did so because a 
flat balance sheet assumption weakened the stress tests by reducing 
required capital. Similarly, when it comes to climate-related stress 
tests, banks will continue to advance arguments that seek to reduce the 
severity of projected losses or the procedural consequences of the 
stress tests. Regulators must see the arguments for what they are.
    Supervision
    Banking regulators should clearly define climate-related 
supervisory expectations for banks. As Governor Lael Brainard stated 
recently, ``Supervisors have a responsibility to ensure that financial 
institutions are resilient to all material risks-including those 
related to climate change-both currently and into the future.''\108\ It 
is critical for banks to integrate climate risk into their governance, 
risk management, internal controls, capital planning, and self-run 
scenario analyses. The banking regulators should integrate these 
expectations into supervisory guidance, supervisory manuals, and the 
supervisory ratings systems.
    Governance: The board of directors and senior management should 
clearly assign responsibilities for climate-related risks within the 
bank's governance structure. This issue requires attention at the 
highest levels of the bank to ensure that climate-related factors are 
being appropriately integrated throughout the bank's core business and 
risk functions.
    Risk Management: Banks should have the policies and procedures in 
place to identify, evaluate, report, and mitigate climate-related 
risks. Both the physical and transition-related risks associated with 
climate change pose serious credit, market, liquidity, reputational, 
and operational risks for many banks. It is vital for banks to account 
for all of these risks in their core risk management frameworks.
    Internal Controls: It is important for banks to have the policies 
and procedures in place to effectively monitor the integration of 
climate-related factors into core risk and business functions. Strong 
internal controls can help the bank evaluate the effectiveness of 
climate-related risk management, governance, capital planning, model 
use, compliance, audit and other functions, and address any clear 
deficiencies in a timely manner.
    Capital Planning: As part of the normal capital planning process, 
in which banks evaluate their capital needs and determine how to manage 
their capital resources, banks should take climate-related risks into 
account.
    Scenario Analyses: While the Fed should establish supervisory 
stress tests, banks should be expected to conduct their own company-run 
stress tests and scenario analyses. The Fed will only use a handful of 
the thousands of potential climate-related scenarios that could play 
out. It's important for banks to think through and attempt to model a 
wide range of potential scenarios.
    Capital Requirements\109\
    Banking regulators should use capital requirements to address both 
the microprudential and macroprudential risks posed by climate change.
    Banking regulators should first focus on the credit and derivative 
exposures that face the most pronounced transition-related risks: 
fossil fuel assets and infrastructure. Bonds, loans, and derivative 
transactions for companies that derive a meaningful portion of their 
revenue from the extraction, exploration, transportation, storage, 
exporting, or refining of oil, natural gas, or coal should be the top 
priority. The risk-weights should be calibrated based on several 
factors, including: (i) the extent to which the company generates 
revenue from fossil fuel-related activities; (ii) differentiation in 
transition risk intensity among oil, gas, and coal exposures; and (iii) 
the length of the exposure. Regulators could also incorporate 
additional variables, such as treating financing for new and existing 
fossil fuel reserves and infrastructure differently, but should not 
spend years trying to over-engineer the risk-weights and adding 
needless complexity. Next, banking regulators should use the 
information gleaned from enhanced corporate climate risk disclosure and 
climate-related stress testing to make additional transition risk 
adjustments to the risk-weighted capital framework. Financial 
instruments tied to other carbon intensive sectors are also susceptible 
to transition risks, including the utility, transportation, mining, 
chemical production, and metal and mining, building materials, and 
agricultural sectors.\110\ In addition, regulators could use stress 
testing and engagement with climate scientists and climate economists 
to improve modeling approaches regarding the physical risks of climate 
change and increase risk-weights for the most exposed assets 
accordingly.
    In order to bolster big banks' resilience to the systemic risks 
they are inflating, and to require them to internalize these external 
costs they are placing on others, banking regulators should also 
implement a macroprudential climate risk contribution capital 
surcharge. This additional riskweighted and leverage capital buffer 
should apply to bank holding companies with more than $100 billion in 
assets and nonbank financial companies designated by the Financial 
Stability Oversight Council (FSOC) as systemically important. The 
climate capital surcharge should be calibrated based on a firm's 
climate risk contribution score, which would measure the bank's level 
of financed GHG emissions, including emissions from its lending, 
underwriting, trading, and off-balance sheet activities.
    The capital surcharge that applies to global systemically important 
banks (G-SIBs) provides a useful conceptual example of how bank capital 
requirements can be used to mitigate a financial externality.\111\ The 
basic formula for the expected losses that a bank places on the 
financial system and broader economy is a function of the bank's 
probability of default, or its likelihood of failure, and its loss-
given default, or the losses that would be placed on the financial 
system or economy if it failed. The failure of a large, complex, and 
interconnected bank would have a much greater negative impact on the 
financial system and broader economy than the failure of a smaller 
bank.\112\ Thus, the loss-given default of a larger bank is much higher 
than that of a smaller bank. Assuming the probability of default is 
generally equal, the expected loss of a large systemic bank is higher 
than that of a small bank. The G-SIB surcharge was designed to bring 
the expected loss for systemic banks in line with those of smaller 
banks by lowering their probability of default through raising their 
capital requirements. When the G-SIB surcharge rule was finalized, 
former Federal Reserve Chair Janet Yellen stated, ``A key purpose of 
the [G-SIB] capital surcharge is to require the firms themselves to 
bear the costs that their failure would impose on others''.\113\ The 
Fed also noted that a related goal of the G-SIB surcharge was to 
``create incentives for SIFIs to shrink their systemic footprint, which 
further reduces the risks these firms pose to financial 
stability.''\114\
    Using the expected loss framing, financing emissions is effectively 
contributing to an increase in the probability of default, and expected 
loss, of the financial system as a whole. Banks that are major 
financiers of carbon-intensive activities are facilitating increased 
GHG emissions and intensifying climate change. Exacerbating the climate 
crisis will increase both the physical and transition risks of climate 
change and inflict larger losses on the financial system. With respect 
to physical risks, higher GHG emissions lead to higher global 
temperatures, which in turn cause more frequent and severe extreme 
weather events and damaging environmental changes.\115\ The more 
significant the physical effects of climate change, the more likely and 
severe the financial system's associated losses will be. Furthermore, 
increased emissions today drive up projected warming pathways and 
increase the likelihood that a rapid and disruptive transition is 
required to stabilize global temperatures.\116\ Firms should be 
required to internalize these costs and the capital surcharge would 
disincentivize risky carbon-financing activities.
    Community Reinvestment Act
    The banking regulators should also look to their obligations under 
the Community Reinvestment Act to help drive mitigation and adaptation 
efforts in low- and moderate-income communities, and communities of 
color. Regulators should use race and environmental justice metrics to 
better target CRA assessment areas.\117\ Regulators should also clarify 
the types of adaptation and mitigation activities that qualify for 
credit under the CRA, including energy efficient affordable housing, 
community solar projects, and green infrastructure.\118\ It is also 
vital for regulators to strengthen the overall enforcement and 
accountability of the CRA to ensure it is meeting the needs of these 
communities, as intended by the statute.
    State insurance regulation
    State insurance commissioners should require insurance companies 
operating in their state to disclose their fossil fuel investments and 
underwriting activities. This disclosure would improve regulators', 
investors', and the public's understanding of insurers' exposure and 
contribution to the climate crisis. Regulators should ensure companies 
set targets and pathways to reduce those high-emissions activities. The 
FIO should issue a data call to collect this information from the 
insurance industry if state insurance commissioners do not use their 
authorities to act.
    Commissioners should establish climate-risk stress tests and 
scenario analyses to help quantify climate-related risks on an 
industry-wide and company-by-company basis-and create stronger risk 
management rules and supervision based on the results. The stress tests 
should gauge the short- and medium-term resiliency of insurers' balance 
sheets in the face of both physical and transition risks. Longer term 
scenario analyses could complement the stress tests by probing how 
insurance companies plan to shift their asset allocation and business 
practices to align with different warming scenarios over a longer time 
horizon. The FIO should evaluate these stress testing frameworks and 
make recommendations to state insurance regulators on best practices 
around scenario design and supervisory models, where appropriate.
    Climate-related risks should also be integrated into the risk-based 
capital (RBC) framework for insurers. The RBC requirements are meant to 
ensure the resilience of insurers and are calculated based on the 
riskiness of their assets and underwriting activities. Increasing the 
loss-absorbing capital required for assets and underwriting activities 
that are most exposed to climate-related risks would help promote the 
stability of the sector. This policy should focus on insurers' fossil 
fuel investments and underwriting, which both expose insurers to 
transition-related losses and increase the physical risks that will be 
borne by others in the future. In addition, regulators should require 
insurers to include climate-related risks in their Own-Risk and 
Solvency Assessments.
Financial Stability Oversight Council
    As a start, the FSOC should embed a focus on climate change and 
climate-related capabilities into its operating structure. Chartering a 
Climate Risk Committee to handle the portfolio of ongoing climate-
related work would be a good initial step toward this end. Relatedly, 
the FSOC should work with the director of the Office of Financial 
Research (OFR) to establish a Division of Climate Risk Analysis. The 
OFR should spearhead the FSOC's data collection, analysis, and research 
priorities on climate-related financial risks, working with member 
agencies on their needs. These recommendations would complement 
Secretary Yellen's important commitment to establish a ``climate hub'' 
at Treasury. FSOC member agencies should then make it an early priority 
to coordinate on the development of agency-specific commitments to 
integrate climate-related risks into their respective core functions. 
These clear and actionable goals could be developed after consultation 
with the public through an agency request for information and announced 
in advance of the U.N. Climate Change Conference (COP26) in November 
2021, which features a robust private finance agenda.\119\
    Over the long term, the FSOC should use its statutory authorities 
to address any identified gaps with respect to climate-related 
financial risks. The FSOC's Section 120 authority to issue 
recommendations to primary regulators could help pressure regulators to 
act where they have the existing authority to do so. Primary regulators 
have substantial authority to use disclosure requirements, stress 
testing, capital frameworks, supervision, fiduciary obligations, and 
more to mitigate climate-related risks and align the financial system 
with the low-carbon transition. These tools have the power to improve 
the resilience of the financial system to climate-related shocks and to 
facilitate the decarbonization of the economy. The FSOC should stand 
ready to push unwilling regulators to act, or go further, when 
necessary.
    Furthermore, the FSOC should integrate climate-related risk as a 
factor into its designation guidance.\120\ There are currently two 
statutory standards under which a nonbank financial company can be 
designated as systemically important. If a firm's material financial 
distress could destabilize the financial system, it can be designated 
under the first standard. That standard is agnostic to the cause of the 
material distress, so there is not an obvious climate-related 
intersection. Under the second standard, designation can occur if ``the 
nature, scope, size, scale, concentration, interconnectedness, or mix 
of the activities'' of the nonbank financial company could threaten 
financial stability.\121\ Under this standard, therefore, the FSOC 
could evaluate a firm's contribution to climate-related financial risks 
through its carbon-financing activities. Financing high-emission 
activities intensifies climate change and increases physical and 
transition risk-related losses for financial institutions and the 
economy in the future, exacerbating systemic risk. It is unlikely that 
the FSOC would designate any firm solely based on climate-related risk 
considerations, but the council could reasonably add these 
considerations to the calculus under the second standard.
    Separately, the Federal Reserve should apply robust climate-related 
prudential regulation to nonbank financial companies that are 
designated as systemically important under either standard, regardless 
of whether climate considerations are factored into the decision to 
designate them. Depending on the former primary regulator of the 
designated company, it may or may not have faced climate-related 
financial regulation previously. As the new primary prudential 
regulator, the Fed is responsible for bolstering the resilience of 
designated nonbank financial companies, and it is important that these 
systemic firms can weather climate-related shocks, among other risks.
Role of Congress
    Congress has an important role to play in ensuring our financial 
system is resilient to climate-related shocks and is positioned to 
support the low-carbon transition. First, stringent congressional 
oversight of the financial regulators will prove crucial. As outlined 
in this testimony, financial regulators have wide-ranging authority 
under existing law to address climate-related risks. Through letters, 
hearings, investigations, and other mechanisms, Congress can press 
regulators to act with appropriate speed and to deploy their full suite 
of tools to rigorously address these risks. Several members of this 
Committee have been pushing regulators for years, which is one of the 
reasons progress has been made in the past few months.
    Second, if regulators fail to act swiftly enough or refuse to 
implement a robust agenda around climate financial risks, Congress 
should step in and insist they do so. In advance of the 2008 financial 
crisis, regulators refused to use the tools at their disposal to 
address the risks financial institutions were creating and the risks to 
which the financial system was exposed. Several important provisions in 
Dodd-Frank did not create new authorities per se-they required 
regulators to implement policies that could have been implemented under 
precrisis law. If regulators again fail to check a build-up of risk in 
the financial system, Congress should direct them to do so in advance 
of another catastrophe. Several important bills, including those 
authored or cosponsored by members of this Committee, have been 
introduced in the past few years. Some notable recent bills include:

    The Climate Risk Disclosure Act, introduced by Senator 
        Warren and Representative Casten, would direct the SEC to 
        develop a comprehensive mandatory climate risk disclosure 
        framework.\122\

    The Climate Change Financial Risk Act, introduced by 
        Senator Schatz and Representative Casten, would require the Fed 
        to establish a climate-related stress testing framework.\123\

    The Addressing Climate Financial Risk Act, introduced by 
        Senator Feinstein and Representative Casten, would direct the 
        banking regulators to develop climate-related supervisory 
        guidance, direct the FSOC to update its nonbank designation 
        guidance to include climate risk, require a report from the 
        Federal Insurance Office on climate risk, among other 
        provisions.\124\

    Finally, Congress could consider additional policy measures or 
adjustments to financial regulators' mandates to more intentionally 
align private capital flows with explicit climate-related targets. 
Regulators have broad responsibilities to bolster the resilience of the 
financial system to climate-related risks and, if used appropriately, 
those authorities will ensure the financial system serves as a source 
of strength for the economy as it decarbonizes. But the ``risk'' 
framing is somewhat of a constraint and Congress could more directly 
mobilize private capital to achieve climate-policy ends. For example, 
banks could be given green-finance mandates as one of the obligations 
that comes with the special public privileges they are afforded.\125\
Conclusion
    Climate-related risks are building in the financial system and 
financial institutions themselves are exacerbating these risks. It is 
incumbent on U.S. financial regulators to step in and perform the jobs 
Congress assigned to them. Integrating climate-related risks into the 
regulatory and supervisory framework through mandatory disclosure, 
stress testing, supervision, capital requirements, fiduciary 
obligations, and more would bolster the resilience of the financial 
system, mitigate the risks created by financial institutions, and 
position the financial system to support the low-carbon transition. 
These risks are not theoretical, and they are not far off in the 
distance. They are here. Regulators have a chance to address these 
risks head on, before catastrophe strikes. It is critical to learn the 
lessons of the 2008 crisis, move urgently, and avoid a climate-driven 
financial crisis.
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                PREPARED STATEMENT OF NATHANIEL KEOHANE
       Senior Vice President, Climate, Environmental Defense Fund
                             March 18, 2021
Introduction
    Climate change is one of the defining challenges of our time. Its 
impacts become more visible every year, not only in hotter 
temperatures, rising seas, and melting glaciers but also in extreme 
weather: wildfires, heat waves, hurricanes, floods, droughts. The 
economic consequences of these impacts loom large, amounting to 
hundreds of billions of dollars every year to the United States alone 
from current emissions.
    As the world's second-largest emitter and largest historical 
emitters, the United States has an obligation to lead the world in 
addressing climate change by taking action across the U.S. economy. To 
help reduce the risk of catastrophic climate change, in line with the 
latest climate science and with the objectives of the Paris Agreement 
on climate change, the U.S. should achieve net zero emissions across 
the entire economy--the point at which we emit no more carbon pollution 
than we can remove from the atmosphere--by no later than 2050, 
including an interim target of cutting emissions at least 50 percent 
below 2005 levels by 2030. A range of recent analyses demonstrate the 
these goals are achievable with well-designed government policies and 
investments to reduce greenhouse gas emissions from sectors including 
electric power generation, transportation, industry, buildings, and 
fossil fuel production; manage forests, croplands, and rangelands to 
store carbon; and increase the resilience of natural and physical 
infrastructure, especially in coastal areas. \1\
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     \1\ See National Academies of Sciences, Engineering, and Medicine, 
Accelerating Decarbonization of the U.S. Energy System (Washington, DC: 
The National Academies Press, 2021), https://doi.org/10.17226/25932; E. 
Larson, C. Greig, J. Jenkins, E. Mayfield, A. Pascale, C. Zhang, J. 
Drossman, R. Williams, S. Pacala, R. Socolow, EJ Baik, R. Birdsey, R. 
Duke, R. Jones, B. Haley, E. Leslie, K. Paustian, and A. Swan, Net-Zero 
America: Potential Pathways, Infrastructure, and Impacts, interim 
report (Princeton University, 2020). https://perma.cc/Z2ZT-BHLM; 
Environmental Defense Fund, ``Recapturing U.S. Leadership on Climate: 
Setting an Ambitious and Credible Nationally Determined Contribution'' 
(Environmental Defense Fund, 2021), https://perma.cc/3UXP-2EPM.
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    The good news is that study after study has shown that the 
investments needed to put the U.S. economy on a path to net zero 
emissions will also help to strengthen the nation's economy, ensure 
good jobs, and enhance America's competitiveness in the global clean 
energy economy.
    In addition to the massive aggregate economic damages mentioned 
above, there is a growing realization that climate change poses a 
significant risk to the U.S. financial system as well--both potentially 
to the financial system as a whole, as well as to specific types of 
financial institutions in particular sectors and regions. In this 
context, policy makers and financial and prudential regulators have a 
range of tools available that could help to significantly mitigate the 
risk to the financial system, particularly by ensuring greater 
transparency around the nature, magnitude, and distribution of climate 
risk and requiring that regulatory bodies and private companies more 
thoroughly incorporate climate change into their risk management and 
decision making. In addition, in light of the enormous and growing 
demand from private investors for sustainable and climate-friendly 
investing, policy makers and regulators can take steps to reduce the 
barriers to such investing.
    With this context in mind, my testimony makes three main points.
    First, climate change poses significant risks to the U.S. financial 
system. In detailing these potential risks, I draw extensively on a 
recent report published by the Climate-Related Market Risk Subcommittee 
of the Commodity Futures Trading Commission's Market Risk Advisory 
Committee, of which I was a co-author.
    Second, financial regulators have a clear responsibility to address 
climate risk under their foundational duties and authorities. I put 
special emphasis on the importance of mandatory climate risk 
disclosure, and also discuss a range of other recommendations related 
to incorporating climate risk into risk management practices of 
regulated firms, increasing the relevant expertise of regulators, and 
improving data availability.
    Third, there is significant demand--and opportunity--to channel 
private capital into low-carbon and climate-friendly investment. In 
addition to noting the rising demand among private investors for such 
opportunities, I highlight the single most important thing policy 
makers could do to ensure that private capital flows more efficiently 
to low-carbon opportunities: namely, implementing a fair and effective 
price on carbon across the U.S. economy.
Climate-Related Risks to the U.S. Economy and the Financial System
Economic damages and financial risk
    The impacts of climate change on the U.S. financial system were the 
focus of the Climate-Related Market Risk Subcommittee of the Market 
Risk Advisory Committee of the Commodity Futures Trading Commission, on 
which I served. Along with the other subcommittee members, I was a co-
author of the subcommittee's report, Managing Climate Risk in the U.S. 
Financial System, which was the first of its kind to be released under 
the auspices of a U.S. financial regulator. \2\ The report was 
unanimously approved by the subcommittee's 34 members--experts 
representing banks, asset managers, agribusiness, the oil and gas 
sector, academia and environmental organizations. In this section, I 
draw extensively on that report to discuss climate-related risks to the 
U.S. financial system.
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     \2\ Commodity Futures Trading Commission (CFTC), Managing Climate 
Risk in the U.S. Financial System, Report of the Climate-Related Market 
Risk Subcommittee of the Market Risk Advisory Committee (2020), https:/
/perma.cc/UT9M-FG2Y.
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    The report conveys a stark message to financial institutions, 
regulators, and policy makers: climate change poses serious risks that, 
if ignored, will undermine the financial system's ability to support 
the American economy.
    Other reports have clearly documented the economic damages from 
climate change. The science has improved tremendously over the past 
decade, to the point where we can clearly link severe weather events 
like hurricanes, wildfires, floods, and drought to a warming planet. 
One recent study calculated $1.75 trillion in damages from severe 
weather events since the 1980s. \3\ The National Oceanic and 
Atmospheric Administration (NOAA) estimates that the United States has 
already experienced over $500 billion in direct economic costs from 
extreme weather events since 2015. \4\ Climate change is driving more 
frequent and damaging extreme weather events; 22 high-cost events were 
recorded in this past year alone, with each causing over $1 billion in 
direct economic damage. \5\
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     \3\ Marcy Lowe and Rebecca Marx, Climate Change-Fueled Weather 
Disasters: Costs to State and Local Economies (Datu Research, 2020), 
https://perma.cc/N459-SDH4.
     \4\ Nat'l Oceanic and Atmospheric Admin., Billion-Dollar Weather 
and Climate Disasters: Summary Stats, https://perma.cc/57XB-638E (last 
visited Jan. 27, 2021).
     \5\ Id.
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    Peer-reviewed economic research suggests that by the end of the 
century, total economic damages to the United States from climate 
change could amount to roughly 1 percent of U.S. GDP annually for each 
1 degree Celsius of global mean temperature rise. \6\ Given expected 
economic growth rates, that amounts to a few trillion dollars per year 
in damages by the end of the century in real terms. Those damages would 
be felt across the economy--reducing crop yields in agriculture, 
threatening infrastructure, damaging coastal real estate, reducing 
labor productivity, and increasing heat-related mortality.
---------------------------------------------------------------------------
     \6\ Solomon Hsiang et al., Estimating Economic Damage from Climate 
Change in the United States, Science 365:1362 (2017), https://perma.cc/
UN9D-PRYS.
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    But even very large economic damages do not necessarily translate 
into risk to financial institutions. One of the main contributions of 
the CFTC report is to explore the potential financial risks in detail.
Pathways for climate-related risk to financial institutions
    At the macro--or ``systemic''--level, the report discusses how 
climate impacts could conceivably contribute to a financial crisis by 
propagating throughout the economy and undermining the value of 
financial assets, as previously hidden risks are suddenly taken into 
account.
    The report also highlights the possibility that climate-related 
risks may well produce ``sub-systemic'' shocks, defined as those that 
affect financial markets or institutions, or a particular sector, asset 
class or region, but without threatening the stability of the financial 
system as a whole. For example, climate-related extreme weather events 
could pose a risk to financial market operations, via liquidity 
disruptions (as could occur in agricultural commodity futures markets, 
say, as a result of price volatility triggered by drought or other 
extreme weather events in major agricultural states) or by threatening 
the operation of financial market utilities (the flooding of a vault of 
the Depository Trust and Clearing Corporation (DTCC) during Superstorm 
Sandy provides a cautionary tale). \7\
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     \7\ CFTC, Managing Climate Risk in the U.S. Financial System, 30.
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    Financial institutions that hold assets likely to be particularly 
vulnerable to climate change could also be at risk--especially where 
the impacts of climate change are relatively concentrated. The report 
highlights examples of risks to various types of financial institutions 
or asset classes:

    Banks with international loan portfolios in climate-
        vulnerable regions. \8\ A scenario analysis conducted by 10 
        major international banks found that water stress resulting 
        from climate-induced drought could lead to increased loan 
        default losses or credit downgrades for bank portfolios. \9\
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     \8\ CFTC, Managing Climate Risk in the U.S. Financial System, 33.
     \9\ Laurence Carter and Stephen Moss, Drought Stress Testing: 
Making Financial Institutions More Resilient to Environmental Risks 
(U.N. Environment Programme Financial Initiative, 2017), https://
perma.cc/3BRF-CDPV.

    Regional and community banks in coastal areas and other 
        climate-vulnerable regions. \10\ Regional and community banks 
        held 30 percent of commercial real estate loans in 2019. \11\ 
        These loans tend to be geographically concentrated and make up 
        nearly a third of the loan books of small banks (Figure 1). As 
        a result, climate-related disasters that affect commercial real 
        estate in a particular region--such as a severe hurricane 
        season--can have a disproportionate impact on local financial 
        institutions.
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     \10\ CFTC, Managing Climate Risk in the U.S. Financial System, 33.
     \11\ Federal Deposit Insurance Corporation, 2019 Risk Review 
(Washington, DC: Federal Deposit Insurance Corporation, 2019). https://
www.fdic.gov/bank/analytical/risk-review/full.pdf.

    Agricultural banks. \12\ Nearly half of all agricultural 
        loans are held by lenders with at least one-quarter of their 
        portfolio concentrated in farm-related areas, such as operating 
        loans or real estate loans (Figure 2). Many of these lenders 
        also have correlated risks because of loan concentrations in 
        particular geographies or related agricultural businesses. 
        Following severe flooding in the spring of 2019, for example, 
        lenders in the Midwest reported to the Federal Reserve Bank of 
        Chicago that 70 percent of their borrowers were moderately or 
        severely affected by extreme weather events. That year, the 
        portion of the region's agricultural loan portfolio reported as 
        having ``major'' or ``severe'' repayment problems hit the 
        highest level in 20 years. Such occurrences are likely to 
        become more frequent and severe as climate impacts continue to 
        grow. A credit-stressed agricultural lending system would 
        decrease farmers' access to affordable credit and increase the 
        difficulty in recovering from climate-related shocks.
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     \12\ CFTC, Managing Climate Risk in the U.S. Financial System, 35.
    [GRAPHICS NOT AVAILABLE IN TIFF FORMAT]
    
    Municipal bonds. \13\ Municipal bonds, used to help finance 
        local governments and held by a wide variety of mutual funds, 
        banks, insurance companies, households, and non-profit 
        organizations, could also be at risk in climate-vulnerable 
        regions. An analysis by BlackRock estimated that in roughly the 
        next decade, municipalities issuing more than 15 percent of the 
        S&P National Municipal Bond Index could face climate-related 
        GDP losses of 0.5 to 1 percent annually--with that figure 
        rising to 40 percent of municipalities suffering losses of 3 
        percent or more by the end of the century. \14\ These impacts 
        could have significant implications for the ability of 
        municipalities to service their obligations--raising the 
        financial risk to bondholders.
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     \13\ CFTC, Managing Climate Risk in the U.S. Financial System, 36.
     \14\ Ashley Schulten et al., Getting Physical: Scenario Analysis 
for Assessing Climate-Related Risks (BlackRock Investment Institute, 
2019), https://perma.cc/3J5C-7DK6.
[GRAPHICS NOT AVAILABLE IN TIFF FORMAT]

    Table 1 on the previous page, taken from the CFTC report, presents 
a comprehensive list of assets exposed to climate change. It reveals 
the breadth of climate risk, including assets like mortgage-backed 
securities, real estate investment trusts (REITs), utility debt, 
insurance equities, and bonds; and sectors including agriculture, 
airlines, automobile manufacturers, hospitality, power generation, and 
concrete and steel.
    Who bears these risks? Some risk is borne by regular investors--
those without the information, analytical resources, or access to 
proprietary data to allow them to identify and respond to hidden risks 
from climate change. .Some risk is borne by the regional financial 
institutions and the people who depend on them: small businesses with 
commercial real estate mortgages, farmers needing loans from 
agricultural credit institutions, and so on. In other words, this isn't 
just about big banks on Wall Street; this is about everyday 
transactions on Main Street: the home mortgages, commercial real estate 
loans, farm credit, and small business loans that underpin the U.S. 
economy--and that depend on a stable financial system.
    How likely are those risks? The scary answer is: We don't know. The 
report shows a range of scenarios for how climate change could threaten 
the U.S. financial system, but we don't know when or how those 
scenarios could occur--because we are not requiring businesses and 
financial institutions to assess, measure, manage, and disclose those 
risks. Recent research from the Brookings Institution, aptly titled 
``Flying Blind,'' makes the same point: investors don't know the actual 
climate risks to their portfolios. \15\ Members of the financial 
community who ignore climate change--whether they are banks, investors 
or regulators--do so at their own peril.
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     \15\ Parker Bolstad et al., Flying Blind: What do Investors Really 
Know About Climate Change Risks in the U.S. Equity and Municipal Debt 
Markets? (Brookings Institute, 2020), https://perma.cc/8LNV-BEGK.
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    That's precisely why measuring and managing climate risk should be 
an essential part of the actions regulators take to protect the 
financial system. I now turn to the role of regulators.
The Duties and Authorities of Financial Regulators To Respond to the 
        Risks of Climate Change
Climate change and the foundational duties and authorities of financial 
        regulators
    Effective financial regulation relies upon multiple and overlapping 
federal and state regulatory regimes and regulators, each working to 
achieve a diversity of statutory goals and objectives. Those duties and 
obligations vary, but generally require agencies to ensure ``market 
efficiency and integrity, consumer and investor protections, capital 
formation or access to credit, taxpayer protection, illicit activity 
prevention, and financial stability.'' \16\ These broad statutory 
obligations require financial regulators to ensure a variety of 
safeguards are present. Transparent and fairly enforced market rules 
support market integrity. Reducing information asymmetries, ensuring 
accurate and comprehensive information, and requiring robust disclosure 
improves efficiency. Preventing losses to the American taxpayer is 
likewise of crucial importance. And financial stability, considered in 
the context of systemic risk and synergistic events, is core to 
regulatory responsibility.
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     \16\ Marc Labonte, ``Who Regulates Whom? An Overview of the U.S. 
Financial Regulatory Framework'' (Congressional Research Service, 
2020), https://perma.cc/NXT4-V3RU, ii.
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    Climate change is highly relevant to the various statutory 
obligations for financial regulators identified above: market 
efficiency and integrity can only be maintained when market 
participants are aware of climate risks to regulated entities and 
investments; taxpayer losses can only be prevented when the effects of 
climate change are considered; and financial stability can only be 
maintained when systemic risks like climate change are proactively 
addressed. More generally, risk identification, reduction, and 
allocation guide regulatory oversight and should extend to 
consideration of climate impacts. For these reasons, financial 
regulators should take proactive action to consider how the 
consequences of climate change implicate their statutory duties and 
authorities.
    The consequences of climate change increasingly implicate these and 
other statutory duties of financial regulators. Put simply: Asserting 
that financial regulators have an obligation to regulate climate risk 
is not based on a reinterpretation of the duties of those regulators. 
Those duties remain the same. What is ``new'' is the magnitude of the 
risk posed by climate change.
The need for mandatory disclosure of climate-related financial risk
    As described above, financial regulators have long required 
requisite levels of transparency and accountability from regulated 
entities. Safeguards to ensure accurate and comprehensive information 
are necessary to the U.S. economy and convey critical benefits across 
stakeholders. Duties and authorities under federal securities law 
serves as one pressing example, with the SEC statutorily obligated to 
protect investors, facilitate capital formation, and maintain fair, 
orderly, and efficient markets. \17\
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     \17\ National Securities Markets Improvement Act of 1996, Pub. L. 
No. 104-290, 110 Stat. 3425 (adding 15 U.S.C. 77b(b) to the Securities 
Act of 1933 and 15 U.S.C. 78c(f) to the Securities and Exchange Act of 
1934).
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    To discharge these core duties, the SEC requires, among other 
things, that regulated entities disclose material risks. As 
demonstrated in section 2, climate change increasingly poses a material 
risk to a broad swath of the economy. The consequences of climate 
change are already creating significant and foreseeable financial 
harms, and disclosure is necessary to ensure investors are aware of the 
physical and transition risks that corporations they invest in may 
face, as well as the potential implications of that exposure.
    Although climate related financial risks are growing, current 
disclosure regimes in the United States have not kept pace. SEC 
guidance in 2010 was important and pathbreaking but has proven 
insufficient, with resulting disclosures lacking in specificity, 
submitted with boilerplate language, or missing entirely. \18\ In the 
absence of effective regulation, voluntary standards and frameworks 
have emerged. Although these efforts, including those by the Task Force 
on Climate-related Financial Disclosures (TCFD) and the Sustainability 
Accounting Standards Board (SASB) have been critical to advancing 
climate risk disclosure, they are insufficient. Recent study has found 
that although climate risk disclosure has increased, ``[m]ore firms are 
disclosing more general information that is essentially of no utility 
to the marketplace.'' \19\ In addition, disclosure varies across 
sectors and some sectors that are particularly vulnerable to climate 
impacts, such as agriculture, are lagging in their assessment and 
disclosure of climate risks. \20\
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     \18\ Sustainability Accounting Standards Board, The State of 
Disclosure 2017: An Analysis of the Effectiveness of Sustainability 
Disclosure in SEC Filings (2017), https://perma.cc/USC8-2HN2, p. 2.
     \19\ Parker Bolstad et al., ``Flying Blind'', 3.
     \20\ Agricultural lenders cite their largest risks as commodity 
prices, production costs, farmland values and global market issues. 
U.S. Bd. of Governors of the Fed. Reserv. Sys., Div. of Banking 
Supervision and Regul., SR 11-14: Supervisory Expectations for Risk 
Management of Agricultural Credit Risk (2011), https://perma.cc/LT4G-
2D6T.
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    To address this vulnerability, the SEC should take action to 
strengthen mandatory climate risk disclosure. Doing so furthers the 
Commission's statutory duties and provides benefit not only to 
investors, but to regulatory companies, the market, and the American 
public. First, investors benefit generally when risks are disclosed, 
insofar as ``investors can only price the risks that they are aware 
of,'' and understanding climate risk exposure ``requires more granular 
data than is currently disclosed in financial reporting.'' \21\ Useful 
climate risk information thus serves an investor's interest in 
effectively allocating capital on the basis of a robust understanding 
of reward and risk. Second, companies benefit in at least three ways: 
``the improved ability: (i) to identify, assess, manage, and adapt to 
the effects of climate change on operations, supply chains and customer 
demand; (ii) to relay risk and opportunity information to capital 
providers, investors, derivatives customers and counterparties, 
markets, and regulators; and, (iii) to learn from competitors about 
climate-related strategy and risk management best practices.'' \22\
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     \21\ Madison Condon, Market Myopia's Climate Bubble, 2021, Utah L. 
Rev. (forthcoming 2021) (manuscript at 6-7), https://papers.ssrn.com/
sol3/papers.cfm?abstract-id=3782675.
     \22\ CFTC, Managing Climate Risk in the U.S. Financial System, 87.
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    Third, strengthened climate risk disclosure benefits markets 
themselves, and climate risk disclosure is relevant to facilitating 
capital formation and maintaining fair, orderly, and efficient markets. 
As noted above, prices that incorporate all information about a 
corporation's financial prospects improve investors' ability to 
distribute capital to its highest value use. Without sufficient 
disclosure, widespread mispricing can occur, an outcome that puts 
market structures at risk, where in the absence of accessible and 
accurate information the likelihood of a sudden shift in price 
correction may occur. Financial experts have warned that consequent 
``sharp changes in valuations'' of corporate entities could in turn 
lead to cascading instability across the financial sector. \23\
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     \23\ Mark Carney, Gov., Bank of England, Chair, Fin. Stability 
Bd., Resolving the Climate Paradox, Arthur Burns Memorial Lecture 
(Sept. 22, 2016), https://perma.cc/6GPS-VWVU.
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    Fourth, climate risk disclosure also conveys crucial benefit to the 
American public: transparent disclosure of climate risk and 
incorporation of that information supports public planning; better 
understanding of physical climate risk and thoughtful resilience 
planning can reduce damage; and strengthened climate risk disclosure 
has the potential to support mitigation efforts. \24\
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     \24\ Benedikt Downar, Jurgen Ernstberger, Stefan Reichelstein, 
Sebastian Schwenen, and Aleksandar Zaklan, ``The Impact of Carbon 
Disclosure Mandates on Emissions and Financial Operating Performance'', 
(Stanford Steyer-Taylor Center for Energy Policy and Finance, 2020), 
https://law.stanford.edu/publications/the-impact-of-carbon-disclosure-
mandates-on-emissions-and-financial-operating-performance/.
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    For these reasons, the consequences of climate change should be 
brought level with other forms of financial risk and mandatory 
disclosure rules strengthened. Boilerplate filings are not adequate, 
and disclosure should drive comparable, specific, and decision-useful 
information from regulated entities. These three tentpoles of 
strengthened disclosure necessarily overlap, but each conveys 
particular meaning: comparability enables benchmarking and risk 
relational across companies; specificity encourages granular analysis 
particular to that entity; and decision-useful design, meant to broadly 
contemplate not only investment determinations but also, for example, 
ownership, engagement, and proxy voting-related decisions, is crucial. 
\25\
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     \25\ Madison Condon et al., Mandating Disclosure of Climate-
Related Financial Risk (NYU Institute for Policy Integrity and 
Environmental Defense Fund, 2021), https://perma.cc/2USW-MMXF, p. 11.
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    The SEC has recently taken positive and important steps to consider 
where and how climate change implicates its statutory duties and 
obligations, including focusing staff attention on the subject and 
requesting public input on climate risk disclosure. \26\ These efforts 
should lead to mandatory comparable, specific, and decision-useful 
climate risk disclosure.
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     \26\ Acting Chair Allison Herren Lee, Public Input Welcomed on 
Climate Change Disclosures, U.S. Securities and Exchange Comm'n (Mar. 
15, 2021), https://perma.cc/U9VA-RZW3.
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Additional recommendations for incorporating climate risk into 
        financial regulation
    As described above, climate change implicates multiple financial 
regulators and a variety of statutory obligations and duties. In this 
context, a few additional examples of specific agencies actions are 
identified below. These actions are described here to highlight the 
varying ways in which climate change interacts with regulatory 
responsibility and identify a few potential priorities, without 
representing an exclusive list.
    Add climate risk expertise
    First, the Treasury Department and the Financial Stability 
Oversight Council (FSOC) should act swiftly to add climate risk 
expertise. The consequences of climate change as a systemic risk could 
be explicated through these bodies, and FSOC may additionally serve as 
an entity well-suited to convene an interagency working group to 
consider climate scenario analyses. Such action would have precedent: 
FSOC has previously created interagency working groups to better 
understand potential risks of specific activities and actions to 
financial stability. \27\
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     \27\ Press Release, Dep't of Treasury, Financial Stability 
Oversight Council Releases Statement on Review of Asset Management 
Products and Activities (Apr. 18, 2016), https://perma.cc/M9T9-M9J5.
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    Likewise, the Federal Reserve should continue efforts to improve 
its internal expertise on climate risk. In its 2020 Financial Stability 
Report, the Federal Reserve classified climate change as a ``near-term 
risk to the financial system that will likely increase financial shocks 
and financial system vulnerabilities.'' \28\ Similarly, the Fed has 
recently stated that ``Federal Reserve supervisors are responsible for 
ensuring that supervised institutions operate in a safe and sound 
manner and can continue to provide financial services to their 
customers in the face of all types of risks, including those related to 
climate change.'' \29\
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     \28\ https://www.federalreserve.gov/publications/2020-november-
financial-stability-report-near-term-risks.htm
     \29\ ``Supervision and Regulation Report'', Board of Governors of 
the Federal Reserve System, November 2020, https://
www.federalreserve.gov/publications/files/202011-supervision-and-
regulation-report.pdf.
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    Require bank and nonbank financial firms to incorporate climate 
risk more broadly
    Under its supervisory authority, the Federal Reserve should require 
financial institutions to incorporate consideration of climate-related 
financial risk into existing risk management and governance frameworks. 
As recommended in the CFTC report, the Fed should also begin to explore 
incorporating climate risk into stress testing, for example through a 
pilot climate risk stress testing program in conjunction with financial 
institutions--following the lead of other jurisdictions such as the 
U.K., and drawing on the work of the Central Bank and Supervisors 
Network for Greening the Financial System (NGFS). \30\
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     \30\ CFTC, Managing Climate Risk in the U.S. Financial System, 44-
45 and 51-52.
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    Promote broader availability and consistency of climate data
    To inform these stress tests and help ensure consistency in 
reporting, regulators should work with a range of stakeholders to 
support the widespread public availability of consistent, comparable, 
and reliable climate data and analysis, including via open source 
platforms, and to develop standardized, consistent, broadly applicable 
climate scenarios. \31\
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     \31\ See discussion of data needs and scenario analysis in CFTC, 
Managing Climate Risk in the U.S. Financial System, Chapters 5 and 6.
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Opportunities for Moving Private Capital to Address Climate Change
The role of the private sector in promoting climate-friendly and 
        sustainable investment
    Over the past five years, private capital has increasingly flowed 
towards climate-friendly assets, as part of a broader shift to take 
environmental, social, and governance (ESG) factors into account in 
investing. Between 2016 and 2018, ESG investing (often referred to as 
``sustainable'' investing) in the US grew by more than 38 percent. \32\ 
Sustainable investments now account for approximately one third of all 
assets under professional management in the US, totaling $17.1 trillion 
as of November 2020. \33\ These trends are driven in large part by 
increasing demand: 85 percent of investors across all age groups 
express interest in sustainable investing. This number rises for 
younger populations: 95 percent of millennials have a stated interest 
in sustainable investing and 89 percent actively expect their financial 
advisors to assess a company's ESG profile before making an investment 
recommendation. \34\
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     \32\ US SIF, Sustainable Investing Basics, https://perma.cc/2E9F-
PTEN.
     \33\ US SIF, The US SIF Foundation's Biennial ``Trends Report'' 
Finds that Sustainable Investing Assets Reach $17.1 Trillion (Nov. 16, 
2020, 3:24 PM), https://perma.cc/DM2C-YBCX.
     \34\ MSCI, Swipe to Invest: The Story Behind Millennials and ESG 
Investing 7 (2020), https://perma.cc/ZSQ6-PQ6N.
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    Much of the rising demand in ESG and sustainable investing is 
driven by a particular focus on climate change, motivated by an 
interest in helping to combat the physical and transition risks 
presented by climate change as well as the opportunities to generate 
value from low-carbon and climate-friendly investment. The Climate 
Action 100+ initiative, designed to support transition to net-zero 
business strategies, continues to grow, with nearly 550 investors and 
$52 trillion in assets under member management. \35\ These trends 
highlight the immense momentum driving private capital towards climate 
solutions.
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     \35\ ``Climate Action 100+'', Ceres, https://www.ceres.org/
initiatives/climate-action-100.
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    Asset managers and banks also understand that climate change poses 
short-, medium-, and long-term financial risks. As BlackRock CEO Larry 
Fink succinctly wrote in 2020, ``climate risk is investment risk.'' 
\36\ BlackRock is not alone; investors increasingly allocate private 
capital to climate-friendly assets to minimize risk and maximize 
returns. \37\ Indeed, these same underlying forces have prompted 
leading financial institutions to commit to achieving net zero finance 
emissions by 2050. JPMorgan, Morgan Stanley, Goldman Sachs, and 
Citigroup among others have all pledged to slash their financed 
emissions over the coming decades. These commitments portend even more 
climate-aligned capital allocation in the future. However, more action 
is needed.
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     \36\ Larry Fink, Larry Fink's 2020 Letter to CEOs: A Fundamental 
Reshaping of Finance, BlackRock (Jan. 14, 2020), https://perma.cc/8TA7-
VGUM.
     \37\ Jon Hale, Morningstar, Sustainable Funds U.S. Landscape 
Report: More Funds, More Flows, and Impressive Returns in 2020 (2021), 
https://perma.cc/9SFJ-7NE5.
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    Banks and asset managers can begin reducing financed emissions in 
the immediate term by engaging with companies in carbon-intensive 
sectors such as oil and gas and transportation. In oil and gas, firms 
can monitor, for example, methane emissions, flaring intensity, capital 
expenditures, lobbying, and governance to track progress and allocate 
investment to those that perform well. By establishing time-bound 
climate benchmarks with consequences for high impact sectors, investors 
can accelerate the deployment of private capital to climate solutions. 
\38\ Banks and asset managers should also direct financing towards 
activities that simultaneously reduce greenhouse gas emissions and 
build the underlying asset's climate resilience. For example, private 
investments in climate-resilient agricultural production can reduce 
agriculture's greenhouse gas emissions while reducing production risks 
from severe weather impacts. \39\
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     \38\ Ben Ratner and Erin Blanton, Five Key Climate Metrics for the 
Oil and Gas Sector's Next Five Years, World Economic Forum (Nov. 2, 
2020), https://perma.cc/U3RL-KMXF.
     \39\ Maggie Monast, Financing Resilient Agriculture: How 
Agricultural Lenders Can Reduce Climate Risk and Help Farmers Build 
Resilience (Environmental Defense Fund, 2020), https://perma.cc/BF4G-
A55W.
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The role of government policies in channeling private capital into 
        climate solutions
    Carbon pricing
    The most important step that government could take to help channel 
private capital into low-carbon investment is to implement policies 
that put a fair and effective price on carbon emissions. Every ton of 
carbon dioxide and other greenhouse gases imposes a cost on society as 
a whole. Using the U.S. government's current central estimate of the 
social cost of carbon--the estimate economic damages from a ton of 
carbon dioxide emitted today, calculated into the future and discounted 
back to today--is $51 per ton. \40\ Given total U.S. CO2 emissions of 
more than 5 billion tons, that implies an annual cost on the order of a 
quarter of a trillion dollars per year. Moreover, there are strong 
reasons to think that the current estimate of the social cost of carbon 
is too low. \41\ In the absence of effective government policies, 
however, that cost is not reflected in market prices--and therefore is 
missing from the financial returns to investors.
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     \40\ United States Government Interagency Working Group on Social 
Cost of Greenhouse Gases, Technical Support Document: Social Cost of 
Carbon, Methane, and Nitrous Oxide Interim Estimates under Executive 
Order 13990 (February 2021), https://www.whitehouse.gov/wpcontent/
uploads/2021/02/
TechnicalSupportDocument_SocialCostofCarbonMethaneNitrousOxide.pdf.
     \41\ K.D. Daniel, R.B. Litterman, and G. Wagner, Declining CO2 
price paths, Proceedings of the National Academy of Sciences 116(42) 
(2019), 20886-20891; R.L. Revesz, P.H. Howard, K. Arrow, L.H. Goulder, 
R.E. Kopp, M. Livermore, and T. Sterner, Global warming: Improve 
economic models of climate change, Nature, 508(7495) (2014), 173.
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    As a result, without a price on carbon, private markets will fail 
to direct capital efficiently. In the words of the CFTC report:

        Without an effective price on carbon, financial markets lack 
        the most efficient incentive mechanism to price climate risks. 
        Therefore, all manner of financial instruments-stocks, bonds, 
        futures, bank loans-do not incorporate those risks in their 
        price. Risk that is not quantified is difficult to manage 
        effectively. Instead, it can build up and eventually cause a 
        disorderly adjustment of prices. \42\
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     \42\ CFTC, Managing Climate Risk in the U.S. Financial System, 4.

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    For this reason, the CFTC report recommends that

        The United States should establish a price on carbon. It must 
        be fair, economywide, and effective in reducing emissions 
        consistent with the Paris Agreement. This is the single most 
        important step to manage climate risk and drive the appropriate 
        allocation of capital. \43\
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     \43\ CFTC, Managing Climate Risk in the U.S. Financial System, 9.
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    Supporting climate-focused and sustainable investing
    While interest in ESG and sustainable investing is increasing, the 
data underlying ESG products remains inconsistent in terms of quality 
and availability. ESG investing remains relatively opaque, with no 
shared industry definition on ``sustainability.'' As a result, ESG-
branded products can contain companies that perform poorly on climate, 
and comparability between ESG rating systems is difficult to achieve. 
\44\ More generally, investors face difficulties engaging companies on 
decarbonization strategies when they lack relevant climate information. 
Strengthened mandatory disclosure by the SEC, as described above, could 
help address these issues, driving more private capital to climate-
friendly assets.
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     \44\ Dane Christensen et al., ``Why is Corporate Virtue in the Eye 
of the Beholder? The Case of ESG Ratings'', 96 The Acct. Rev. 
(forthcoming 2021), https://perma.cc/Q8X3-5QUV.
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    Government policies should also acknowledge the relevance of ESG 
factors, including climate-related factors, to investors and allow them 
to be better integrated into retirement planning. Demand for 
sustainable retirement funds is high; 74 percent of employees feel that 
having socially responsible investment options in their 401(k) plans is 
important. Roughly 2/3rds of all millennials would increase their 
retirement plan contribution if they knew their investments were doing 
social good. Retirement plans are a significant vehicle for individual 
investors to realize their goals: while only 14 percent of Americans 
are directly invested in individual stocks, over half have access to 
401(k) plans. \45\ Yet despite clear interest in sustainable 
investment, less than 3 percent of 401(k) plans include an ESG option 
and only .1 percent of 401(k) assets are ESG-aligned. \46\
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     \45\ https://www.pewresearch.org/fact-tank/2020/03/25/more-than-
half-of-u-s-households-have-some-investment-in-the-stock-market/
     \46\ Greg Iacurci, Climate Funds Hold Less Than 1 percent of 
401(k) Money. Here's Why, CNBC (Dec. 14, 2020), https://perma.cc/D892-
JMEN.
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    Promoting better integration of ESG and climate-focused factors in 
the $6.6 trillion 401(k) market would provide millions of Americans 
with access to funds that generate superior long-term returns, align 
with their values, and protect the planet. The Department of Labor 
(DOL), under the Employee Retirement Income Security Act (ERISA), 
oversees minimum standards for retirement plans in the United States, 
and should consider rulemaking and/or other actions that could support 
climate-aligned investment by better integrating ESG and sustainability 
factors in ERISA plans. In particular, DOL should consider formally 
acknowledging existing evidence that climate-related risks are 
financially material, in order to clarify existing regulations for plan 
fiduciaries and reduce uncertainty that can hinder the inclusion of 
climate-relevant factors into plan offerings.
Conclusion
    Climate change poses significant risks to the U.S. financial 
system--but well-designed policies can help to manage and mitigate 
those risks. As policy makers consider how to address the challenge of 
climate change and position the U.S. economy for robust, inclusive 
growth in coming decades, they have a range of tools available. Given 
the central importance of accurate, consistent, and up-to-date 
information, regulators should put particular importance on mandatory 
climate risk disclosure, as well as incorporating climate risk into 
risk management practices of regulated firms, increasing the relevant 
expertise of regulators, and improving data availability. In addition, 
well-designed policies can help remove barriers that limit the flow of 
private capital into low-carbon and climate-friendly investment 
opportunities, responding to the significant and growing demand from 
investors. In that respect, the most important step policy makers can 
take would be to implement a fair and effective price on carbon across 
the U.S. economy.
                                 ______
                                 
                  PREPARED STATEMENT OF MARILYN WAITE
Climate And Clean Energy Finance Program Officer, The William and Flora 
                           Hewlett Foundation
                             March 18, 2021
Climate Urgency
    The year 2020 marked a turning point in planetary systems--it was 
the warmest year on record, with Death Valley in California reporting a 
maximum temperature of 130 degrees F in August. \1\ The United States 
experienced 22 separate billion-dollar weather and climate-related 
disasters, exacerbating the economic toll of COVID-19 and costing $95 
billion in damages in a single year./2/
---------------------------------------------------------------------------
     \1\ Laura Newberry. L.A. Times, Aug 16, 2020. ``Death Valley Hits 
130 Degrees, Thought To Be Highest Temperature on Earth in Nearly a 
Century''. https://www.latimes.com/california/story/2020-08-16/death-
valley-hits-130-degrees-thought-to-be-earths-highest-temperature-in-
more-a-century
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    As climate change pushes towards higher average global 
temperatures, we will continue to see a variety of sectors hurt: from 
grounded planes in Arizona because it's simply too hot to take off, to 
a dwindling food supply because heavy rain and snow storms in the 
Midwest blanket agricultural land. In an Economic Brief from the 
Federal Reserve Bank of Richmond, researchers explained that rising 
temperatures could reduce overall growth of U.S. economic output by as 
much as one-third by 2100./3/ The impacts of climate change are deep 
and widespread, with no one industry exempt.
    In 2018, the Intergovernmental Panel on Climate Change (IPCC) 
outlined the impacts of climate change at 2.7 degrees F (or 1.5 degrees 
C). The report, which involved 91 authors and drew upon 6,000 research 
papers, emphasized the time-sensitive nature for mitigating climate 
change--we must accelerate action over the next decade to avoid 
significant loss of human, economic and ecosystem life.\4\ In order to 
avert unprecedented upheaval, the global average temperature increase 
from pre-industrial levels must stay at or below 1.5 degrees C. To 
remain within this limit, the global economy must cut annual global 
greenhouse gas emissions 45 percent below 2010 levels by 2030 and reach 
net zero (also known as becoming carbon neutral) by 2050. At the global 
level, this means that, in aggregate, all sources of anthropogenic GHG 
emissions that currently total up to 55 GT of CO2 equivalent (CO2e) per 
year must reach zero. For the United States, which represents about 15 
percent of the world's GDP and GHG emissions, this equates to roughly 6 
GT of CO2e annually.\5\
    If warming is allowed to increase to 4 degrees C in the business-
as-usual scenario, global economic losses from climate change are 
conservatively estimated to be $23 trillion per year-three to four 
times the scale of the 2008 financial crisis and more than three times 
the predicted contraction of global GDP due to COVID-19.\6\ That 
estimate is conservative partly because it does not account for the 
effects of wildfires and other extreme events.
    But we have choices. Another modelled estimate finds the economic 
cost of failing to cut emissions adds up to a burden of between $150 
and $792 trillion by 2100, whereas the net benefit of climate change 
mitigation, on top of avoiding those losses, could be between $127 and 
$616 trillion by 2100.\7\
    In short, it's cheaper to solve the climate crisis than to allow it 
to persist.
    According to a comprehensive study by Princeton University, the 
U.S. must invest an additional $250 billion each year, compared to 
business-as-usual, for the next ten years at a minimum to reach net 
zero by 2050. These investments would target energy supply, industry, 
buildings, and vehicles and could create 1 million new jobs.\8\
Climate-Related Financial Risks
    The impacts of climate change to the financial system manifest in 
multiple ways and can be grouped in both physical and transition risks.
    Physical risk includes damage to properties and assets from the 
changing climate and related extreme weather events. Physical risks, 
whether acute or chronic, can lead to increased capital costs (e.g., 
damage to facilities), reduced revenues from lower sales/output, write-
offs and early retirement of existing assets (e.g., damage to assets in 
``high-risk'' locations), and increased operating costs (e.g., 
inadequate water supply for hydroelectric plants or to cool nuclear and 
fossil fuel plants). Physical risks include both demand and supply-side 
shocks to the financial system. For instance, rising sea levels may 
decrease demand for coastal real estate; saline intrusion of wells may 
impact drinking water supplies.
    Transition risks are losses arising from the transition from a 
fossil fuel-based economy to a clean energy economy. The risks include 
credit risk (loan defaults from stranded assets, technology 
substitution of existing products and services with lower emissions 
options) and market risk (such as impairment of capital market assets), 
and can result in reduced demand for products and services and 
repricing of assets. Transition risks also capture the indirect effects 
of climate change, such as higher prices of raw materials, which may 
lead to less competition among firms, which in turn may lead to greater 
unemployment, which could result in greater insecurity. Taken together, 
once risks have manifested at the institutional and retail level, they 
reach the financial markets, through the classic market, credit, 
liquidity and operational risks.\9\
    Worth special attention is the creation of stranded assets. This 
term describes an asset, such as a piece of equipment or a resource, 
which falls in value or can no longer produce revenue as a result of 
technological developments, market shifts or changing societal 
habits.\10\ For example, by the early 20th century, the market for 
whale oil and oil lamps all but disappeared with the advent of electric 
lighting. The whaling industry's ships and the existing stock of oil 
lamps therefore became stranded assets. Today the term is often used to 
describe oil and gas resources that remain in the ground but appear as 
assets on a firm's balance sheet. Yet stranded assets are not only a 
problem for companies involved in fossil fuel extraction; businesses 
that use fossil fuels as production inputs, or are otherwise energy or 
carbon intensive could also be heavily impacted by climate legislation, 
technological breakthroughs, and a shift in demand as the global 
economy transitions away from fossil fuels.
    In some sectors, such as coal, the stranding of assets has already 
begun due to the relative cost competitiveness of renewables. For 
example, globally, power generation from wind and solar installations 
are now less expensive to operate than coal-with almost 30 percent of 
new coal plants estimated to enter the market cash flow negative from 
their first day of operation.\11\ Furthermore, investors and 
governments alike could find themselves with $630 billion worth of 
stranded assets if the current global pipeline of new coal plant 
construction was to proceed.\12\ If investing continues along a 
business-as-usual path, and the financial system fails to incorporate 
climate risks into its decision-making framework-businesses will 
inevitably end up with stranded assets across numerous sectors.
    As the financial system and the real economy will both be 
devastated if the planet warms much more, and with real losses already 
manifesting in some sectors and asset classes, the challenge goes far 
beyond just protecting the financial system from climate risk. 
Investors and policymakers must choose if and why they should finance 
and back assets that are fundamentally unworkable, inconsistent with 
international agreements such as the Paris Agreement, and are likely to 
be stranded. In the case of coal, it would be wise for policymakers to 
plan now for the retirement of coal assets over the coming 10 years to 
minimize the financial risk of a disorderly energy transition.\13\ The 
financial system, through new market rules, must integrate a shift from 
the single materiality of risk management to the double materiality of 
risk and impact management; this double materiality includes financial 
materiality and environmental and social materiality.\14\
Role of Finance in Solving Climate Change
    Finance is absolutely essential. There will not be a transition to 
a low carbon economy without a way to finance the vast number of 
infrastructure, retrofit, new technology research, and various other 
projects needed. We saw annual climate investment flows rise to $579 
billion, on average, over the 2-year period of 2017-2018, with 
increases concentrated in low-carbon transport, North America, and East 
Asia. Nevertheless, this figure is not enough to maintain a well-below 
2 degrees C of warming target. Estimates of the global investment 
required to achieve that goal range from $1.6 to 3.8 trillion annually, 
for supply-side energy system investments alone.\15\ However 
policymakers as well as businesses know that investments are not only 
associated with costs, they also bring returns and benefits. Therefore, 
while climate change is a significant crisis, it is also a significant 
opportunity to create jobs, wealth, and long-term economic prosperity-
especially in the context of the ongoing U.S. economy's recovery from 
COVID-19.
    In 2018 alone, the U.S. advanced energy industry generated $238 
billion in revenue, which is roughly equal to that of aerospace 
manufacturing and double that of the biotech industry. The market for 
climate-smart technology is expected to grow significantly over the 
coming decade, estimated to be worth $23 trillion by 2030. Clean energy 
installations are also a steady source of state and local taxes-for 
example, wind farms paid $761 million to state and local governments in 
2018 in addition to $289 million to farmers and landowners who leased 
their land to wind turbine operators. Investing $4 billion annually 
into reforestation and sustainable forest management could support an 
estimated 150,000 jobs per year, which is three times as many jobs as 
the logging industry provides.\16\
    At the Hewlett Foundation, we've taken a lead on committing 
significant resources to climate initiatives--and for the first time in 
2018-2023, we dedicated $75 million to Climate Finance and Investment 
grantmaking. This falls within our broader commitment of $600 million 
for climate-focused grantmaking across four key geographies (the United 
States, China, India and Europe) within five sectors including 
Electricity, Transportation and Cities, Industry, Finance/Investment, 
and Technology, Innovation and R&D.
    In developing our Climate Finance Strategy, we studied the 
financial system to better understand where capital was allocated, who 
owned or controlled it, and what the barriers were to financing more 
zero emissions energy, transportation, industry, and land use projects. 
What we found was nearly $250 trillion worth of commercial capital 
available globally in five primary capital pools including: Asset 
Owners, Retail Bank Deposits, Development Finance Institutions (DFI)/
Multilateral Development Banks (MDB), Private Equity and Venture 
Capital. Broadly speaking, each of these pools of capital seek 
different risk/return profiles, comply with different regulations in 
different markets, and perform distinct functions in the global capital 
markets.\17\
    The data clearly show that the problem is not lack of capital. 
Moreover, recent responses to COVID-19 have mobilized trillions from 
national budgets and the capital markets have re-bounded since March 
2020, shifting trillions of dollars from retail and institutional 
investors to listed companies. Yet an estimated one-third of fixed 
income and public equity assets are still linked to climate change 
causing industries.\18\ Therefore, the real challenge is moving those 
trillions to low-carbon investments. Numerous factors hold back this 
investment-entrenched beliefs, thinking, and processes associated with 
traditional methods of investment decision-making hamper action. For 
some investment professionals, false perceptions about investing in 
climate-friendly projects or technologies are common. For others, a 
lack of data or tools makes it too challenging to apply the 
consideration of the impacts and risks associated with climate change 
to their portfolio.
    Through interviews, research and analysis, we identified eight key 
barriers that inhibit the expansion of opportunities to access and 
mobilize finance for climate-friendly activities. These include:

  1.  Limited Sources of High-Risk Capital

  2.  Pricing of Perceived Risks

  3.  Deal Size Preferences

  4.  Lack of Transparent Data

  5.  Policy Uncertainty

  6.  Timing of Climate Risk Impacts

  7.  Lack of climate-friendly investment guidelines

  8.  Short-term investment horizons

    Limited Sources of High-Risk Capital: Early-stage investments 
provide the bridge between the research and development of a technology 
and scaling up. Typically, Venture Capital (VC) funds fill this gap and 
are an integral resource for early-stage investments and helping 
companies scale. Yet VC cleantech investments are heavily skewed 
towards late-stage projects concentrated around energy efficiency, 
transportation and smart grid. As such, 87 percent of VC cleantech 
investments went to late stage projects in 2016.
    Pricing of Perceived Risks: Risks that apply to climate-friendly 
investments are often perceived by investors in vastly different ways. 
This results in a wide variation in pricing and capital availability. 
For example, energy efficiency projects are universally identified as 
critical to solving climate change; yet the inability to finance these 
projects based on the strength of their energy savings has limited 
their deployment. Investors' opinions, not always data, sometimes lead 
to an over reliance on the financial strength of the project hosts, 
which can lead to requiring credit enhancements or complicated 
structures to satisfy investors' concerns over the durability of energy 
savings.
    Deal Size Preferences: The market for larger, centralized projects 
with vetted technologies initiated and supported by utilities, 
governments, corporations and other long-term credit worthy 
counterparties is well known and quite active. Yet, smaller, 
distributed projects-including solar photovoltaic, energy efficiency, 
electric vehicles, and others at the residential, small commercial and 
industrial sectors often have challenges accessing sufficient levels of 
long-term capital. This typically occurs because large institutional 
investors, such as pension funds, traditionally participate in utility 
scale deals on a significantly grander scale-where deals are worth $50 
million or more. This preference for large deals means that relatively 
smaller projects worth $10,000, $100,000, or even $1,000,000 often get 
left out.
    Lack of Transparent Data: A lack of consistent, transparent, and 
available data that reports the technical performance, energy 
production, and environmental impact of climate projects and other 
important factors limits the ability of potential investors to evaluate 
past performance of similar projects. This often results in higher risk 
premiums, which increase interest rates and return requirements and 
simultaneously decreases the number of interested investors. An 
inability to thoroughly assess projects increases hesitation among 
investors as they are further unable to evaluate and reduce perceived 
risk premiums for climate-friendly projects.
    Policy Uncertainty: Further dissuading long-term investment in 
climate-friendly activities is the uncertainty associated with policies 
around climate change. Governments' shifting and sometimes unclear 
commitments to climate-related policy or regulations help to fuel 
investors' unease with entering the sector.
    Timing of Climate Risk Impacts: Many professionals making 
investment decisions do not view climate change as a significant short-
term risk that requires the adjustment of investment and credit 
considerations. The indefinite timing and magnitude of climate change 
impacts are often cited as key impediments to investors' ability to 
consider the financial risks of climate change in near term decision 
making and portfolio allocation methods.
    Lack of Climate-Friendly Investment Guidelines: There is no unified 
definition for climate/ green/sustainable investments; or for climate 
finance activities that provide direct funding towards reaching climate 
goals and reducing GHG emissions. Practically speaking, this means that 
investors cannot easily compare different investment opportunities 
labeled `green' or climate friendly. For example, securities can only 
be listed on the Bloomberg Barclays MSCI Green Bond Index if they fall 
within at least one of six MSCI-defined eligible environmental 
categories: Alternative Energy, Energy Efficiency, Pollution Prevention 
and Control, Sustainable Water, Green Building, and Climate 
Adaptation.\19\
    Short-Term Investor Horizons: Many investment decisions are focused 
on near-term risks and returns. For example, the hold period for 
investments is typically five to seven years, and therefore investors 
minimize risks further off into the future. There is also the 
expectation by many investors for maximum returns over each period they 
hold an investment. This pressure can lead investment managers to 
``chase'' quarterly returns and not properly or fully analyze risk.
    We structured our approach in the Climate Finance Strategy to 
foster and select projects that address one or more of these barriers. 
What we have learned from this work is that there are limits to what 
any one lender, asset owner or asset manager can do within its four 
walls and financial supply chain to enact the changes necessary to 
protect the financial system from climate-related downfall and support 
the low carbon economic transition. Fortunately, there are a number of 
actions that financial regulators and policymakers can take to 
safeguard the planet and people and provide adequate market rules to 
curb climate change.
Financed Emissions Disclosure
    Step one is to mandate more information, but not just any 
information. Financial institutions must be required to measure and 
disclose the carbon emissions of their financial portfolios.\20\ This 
list includes, but is not limited to sovereign bonds, listed equity, 
project finance, mortgages, commercial real estate, corporate debt: 
bonds, business loans, indirect investments, and auto-loans.
    An open access, open source, widely used methodology for measuring 
and disclosing financed emissions comes from the Partnership for Carbon 
Accounting Financials (PCAF). PCAF is an international, industry-led 
initiative that enables financial institutions (FIs) to measure and 
disclose GHG emissions financed by loans and investments. A group of 
banks and investors launched PCAF during Climate Week in New York in 
September of 2019. Currently, over 100 FIs have joined and committed to 
assess and disclose their portfolio's GHG emissions, representing more 
than $25 trillion of assets under management (AUM).\21\ The members of 
PCAF have harmonized an approach to assess and disclose the greenhouse 
gas (GHG) emissions of their loans and investments, accompanied by an 
emissions factor database.
    There is global precedent for mandating financed emissions 
disclosure. For example, in March 2021, The European Banking Authority 
(EBA) issued a draft standard on the prudential disclosures on ESG 
risks, stating that European financial institutions should disclose the 
carbon footprint and scope 3 emissions\22\ of their collaterals by June 
2024.\23\ The European Central Bank (ECB) published, in Section 7.2 of 
its final guide on climate-related and environmental risks for banks, 
that financial institutions are ``expected to disclose the 
institution's financed scope GHG emissions'' and references the use of 
PCAF by a number of financial institutions in line with the GHG 
Protocol.\24\
    Corporate disclosure of climate-related risks and opportunities 
will help investors fulfill their fiduciary obligations to integrate 
material climate considerations into their investment actions. 
Investors need consistent, comparable data, in a machine-readable 
format, so that they can efficiently and effectively aggregate and 
analyze climate-related financial disclosures. The Securities and 
Exchange Commission must update existing disclosure requirements to 
require that reporting companies disclose this data.
Enabling Community-Focused Lenders to Lead
    Communities of color in the country bear the brunt of environmental 
degradation and pollution, and similar to the impacts of COVID-19, are 
likely to be disproportionately impacted by unabated climate change. 
The National Academy of Sciences found that the largest environmental 
health risk factor in the U.S., fine particulate matter (PM2.5), is 
disproportionately caused by consumption of goods and services mainly 
by the non-Hispanic white majority, but disproportionately inhaled by 
Black and Hispanic minorities.\25\ Due to the increased air pollution 
burden, higher likelihood of living in climate risk zones (such as 
flood zones, isolated rural areas, and urban heat islands), higher 
likelihood of living in areas with aging and poorly maintained 
infrastructure, low-income groups, communities of color, and some 
immigrant populations are highly vulnerable to the health impacts of 
climate change.\26\
    In addition to living in communities disproportionately affected by 
pollution and vulnerable to climate change, both rural and urban low-
income households spend three times as much of their income on energy 
than non-low-income households, a phenomenon known as energy 
burden.\27\ In 2015, an estimated 17 million households received an 
energy disconnect/delivery stop notice and 25 million households had to 
forgo food and medicine to pay energy bills.\28\ To help low or 
moderate income (LMI) households mitigate the effects of climate change 
and access renewable energy technologies, community-focused lenders and 
other community-based financing schemes can be leveraged.
    There are over 100 minority depository institutions (MDIs), over 
1,000 community development financial institutions (CDFIs), over 5,000 
credit unions, and over 5,000 deposit-taking banks that are poised to 
serve climate-impacted communities in the United States. However, the 
federal government has a critical role to play in ensuring the 
successful alignment of these institutions with solving climate change. 
There are a number of existing federal programs that need to be updated 
in the short-run to align financial incentives with the clean energy 
transition. For example, the creation of a dedicated clean energy grant 
program as a part of the CDFI fund would be beneficial. There is 
precedence for this approach, with CDFI Funds already having dedicated 
grant program award `buckets' to efforts outside of traditional awards, 
such as the Healthy Foods Financing Initiative and Disability Funds 
Financial Assistance.\29\ This approach would ensure that more CDFIs 
focus on financing clean energy, which in turn boosts innovation and 
impact. As such, dedicated clean energy awards could be structured to 
assist CDFIs to fund solar and energy efficiency loans.\30\
    Credit unions are another powerful source of financing that can be 
deployed to help communities access funds for everything from home 
solar to energy efficiency retrofits and electric vehicles. However, 
what they lack is the technical assistance and the patient capital to 
be able add the `clean energy asset class' to their loan books. A key 
challenge is access to secondary capital for loss absorption. Unlike 
banks, which have different instruments available to them, secondary 
capital for credit unions has historically been provided by 
philanthropic organizations or as loans--with demand significantly 
outstripping supply.\31\
    The National Credit Union Administration (NCUA) should expand 
access to secondary capital, including equity, for credit unions 
engaging in climate mitigation and green opportunity financing, and 
allow credit unions to service small businesses for climate mitigation 
related lending, similar to the current rule for low-income lending. At 
the same time, we see the need for an injection of long-term, low-cost 
capital to enable rapid scaling of credit union's lending capacities in 
the communities most impacted by COVID-19 and climate change. 
Therefore, Treasury should provide direct investment of secondary 
capital into credit unions to support the lending needed for economic 
recovery and long-term climate change mitigation.\32\ Note that this 
approach is not without precedent either. In 2010, Treasury made an 
investment of $70 million to secondary capital for CDFI-certified 
credit unions-where every dollar invested resulted in $60 worth of 
loans over the intervening years.\33\
    Some credit unions such as the Clean Energy (Federal) Credit Union 
and Inclusiv (a network of community development credit unions) are 
already focusing on clean energy and seeing success. For example, in 
its first three years of operations the Clean Energy Credit Union has 
reported zero delinquencies and has sold loan participations across the 
U.S. including Texas, Oklahoma, and Montana. As a low-income designated 
cooperative bank, they are already teaching other credit unions the 
value of this asset class. Similarly, Inclusiv offers green lending 
training for all community-focused lenders along two tracks: 
commercial/project finance and residential/consumer loans. Importantly, 
these existing lenders are financially stable-meaning they pass the 
regulatory tests set by the FDIC and NCUA on an annual basis.
A Bank Mandate for Climate-Mitigating Lending
    An important way to unlock trillions of dollars with zero public 
spending is through mandates, a series of incentives and penalties for 
lenders to meet climate change mitigation lending amounts. The 
Community Reinvestment Act (CRA) provides a precedent for such action. 
The existing CRA can be strengthened to explicitly provide credit for 
climate and clean energy loans. A new mandate that requires banks to 
invest a certain percentage of their assets into climate friendly 
infrastructure can also be instated.
    The CRA seeks to ensure that banks meet the credit needs of their 
entire service territory, including low- and moderate-income 
neighborhoods. The OCC, FDIC and Federal Reserve Board enforce the CRA 
by evaluating depository institutions according to size-differentiated 
rubrics; large banks are scored on the basis of lending, investment and 
service and receive one of four grades: outstanding, satisfactory, 
needs to improve, and substantial noncompliance.\34\
    While the CRA has been largely beneficial to LMI communities, up 
until now it has not focused on addressing environmental justice. 
Incorporating sustainability metrics for LMI communities into the CRA 
would drive new investments and loans to help mitigate disproportionate 
negative impacts and increase LMI community access to the benefits of 
clean energy. The CRA should explicitly include climate-friendly 
investments as allowable activities; this would provide banks and 
financial regulators with better data on how many investments are being 
made and in what areas, which in turn will also likely increase these 
types of investments./35/ The following specific changes to the 
existing CRA would enable more climate capital in underserved 
communities that can serve both wealth-building and climate resiliency 
purposes: 1) extend CRA coverage to non-banks, including credit unions, 
which would expand access to credit in banking deserts,\36\ 2) measure 
financial institution performance by outcomes, including carbon 
emission levels and other criteria for climate justice, 3) create a 
stronger focus on geographic racial and ethnic disparities due to the 
disproportionate impact of climate change on zip codes with high 
concentrations of people of color, and 4) mandate that affordable 
housing (including mixed income units) be sustainable and energy-
efficient for CRA credit.
    In addition to CRA modifications, the following interventions would 
also create climate resiliency and wealth creating opportunities for 
LMI communities: fostering a municipal green bond market that meets the 
Principles of Environmental Justice\37\ and climate-focused New Markets 
Tax Credits.\38\
    The CRA is estimated to mobilize about $300 billion annually to LMI 
communities. Climate is another area of underinvestment and thus 
warrants a CRA-style mandate. Congress can instruct financial 
institutions (FIs), especially SIFIs, to lend and invest in GHG-
reducing activities across financial asset classes. The FIs would be 
rated and these ratings would be taken into account for regulatory 
approvals, including mergers and acquisitions. In addition, FIs that 
fail to meet minimum thresholds for decarbonization could incur fees.
The Nation's Balance Sheet
    During the 2020 economic disruption provoked by the COVID-19 
pandemic, the Federal Reserve made 83 percent of the oil and gas 
industry's mostly below investment grade debt eligible for cheap 
refinancing.\39\ Coal, oil and gas companies received nearly $3.9 
billion in government aid.\40\ The financial regulators, including the 
Fed, thus ignored sound risk management by failing to incorporate 
climate-related financial risks. The Fed is prohibited from making 
investments into companies that are insolvent or likely to become 
so,\41\ yet by extending corporate bond purchases to `junk bonds,' the 
nation's balance sheet has been put in peril. Fossil fuel energy 
companies make up 13 percent of the lowest-rated, riskiest kind of 
corporate debt.\42\ This climate change-causing sector also 
disproportionately relies on heavily leveraged loans, collateralized 
loan obligations, and other low-rated debt.\43\
    Climate risk should be incorporated into Dodd Frank Act stress 
tests in order to have a more accurate picture of financial stability. 
However, the Federal Reserve and other financial regulators should not 
wait on the results of such tests to enact climate finance regulations. 
To lead to material shifts away from the dirty economy towards a clean 
one, a `precautionary' financial policy approach is required. This 
approach takes into account that climate related financial risks are 
different from others--they are endogenous and systemic, irreversible, 
pervasive, and have a high level of uncertainty in terms of very 
specific points of impact.\44\
    The business of risk analysis is generally based on forward-looking 
projections that build on past data and as such, the future is 
conceived as a replication of the past. Climate impacts, which are 
multidimensional, non-linear, and attached to underlying socio-economic 
realities, do not work that way-they exist in the realm of uncertainty, 
whereby the future is ``unknowable and unpredictable.''\45\
    Taking a precautionary approach to climate financial policy, 
policymakers at all levels of government can enact regulations to limit 
the financing of climate change causing activities and incentivize 
climate change solving ones. Therefore, the country's bank, the Federal 
Reserve, and other financial regulators should ensure that the 
financial system is working for climate mitigation. Tools include a 
differential interest rate for carbon intensive lending, different 
capital requirements for carbon intensive lending, and a corporate 
equity and bond purchasing policy that is negatively screened for 
carbon. Not only should policymakers such as the SEC and OCC instruct 
banks and asset managers to measure and disclose their financed 
emissions, but The Federal Reserve itself should also measure and 
disclose the greenhouse gas emissions that it is financing through its 
operations, starting with its emergency lending portfolio in response 
to the coronavirus crisis.\46\ Asset managers and insurance companies, 
through a designation as non-bank SIFIs by the FSOC, can also come 
under supervision and regulation by the Federal Reserve.\47\ The 
Federal Reserve can also take the following measures: 1) require banks 
that own coal, oil and gas assets to retire them, 2) limit banks' 
ability to own and run nonfinancial businesses, and 3) implement higher 
risk-weighted bank capital requirements for assets that are sensitive 
to the price of carbon such as fossil fuels, deforestation, and 
internal combustion engine vehicles.\48\ On the latter, the minimum 
ratios of capital to assets, known as risk-based capital, should 
reflect the potential for losses due to physical and transition climate 
risks. Risk weights could be increased for loans and investments in 
climate change-driving assets, such as the financing of the industries 
that account for most global industrial greenhouse gas emissions in 
coal, oil, gas, and agribusiness tied to deforestation.\49\
Fiduciary Duty
    The market has spoken when it comes to the financial benefit of 
incorporating environmental, social and governance (ESG), including 
climate impact factors, into investment decisions. The majority of ESG 
funds outperform non-ESG counterparts and ESG ETFs doubled in 2020.\50\ 
ESG, including climate mitigation strategies, are preferred by 
investors for a number of reasons, including that this information 
allows for better decision making, better management and mitigation of 
risks, and ultimately the generation of risk-adjusted returns. 
Sustainable investing assets now account for $17.1 trillion-or 1 in 3 
dollars-of the total US assets under professional management. This 
represents a 42 percent increase over 2018.\51\
    Investment in climate change causing industries, such as fossil 
fuels, poses a long-term risk to generating strong returns for a 
diversified portfolio. In the last ten years, the S&P energy sector 
gained just 1 percent as low oil prices, high operational costs and 
changing consumer preferences spurred selling. However, in the same 
time period, the broader market gained 212 percent. Investors and 
lenders now require higher hurdle rates for climate change-causing 
industries since they produce a lower return on investment capital. If 
we look at hurdle rates, coal projects need 40+ percent whereas 
developed market solar and wind need just 10+ percent.\52\ Policymakers 
should therefore protect worker's savings and maximize returns by 
instructing ERISA fiduciaries to incorporate ESG risks and 
opportunities, explicitly climate considerations, into investment 
options.
    Climate change is always material. Fiduciaries, as those 
responsible for acting in their client's best financial interest, would 
be unfit should they not consider such an important and pervasive risk 
as climate change. Climate pollution is not like other sources of air, 
water and land point-source contaminants--GHG emissions are omnipresent 
and impacts are widespread, including in transportation, energy, real 
estate, food production, water and wastewater infrastructure. By 
neglecting climate factors, investors will likely misprice risk and 
poorly allocate assets; this is in part why globally there are over 730 
policies across 500 policy instruments that support or require the 
incorporation of ESG issues in the fiduciary process.\53\
    Policymakers at all levels of government, including state pension 
fund regulators, the SEC, FINRA, and the Department of Labor (DOL), 
should modernize fiduciary duty definitions to align with ESG, 
including climate risk and impact. Climate specific fiduciary 
regulations should include retirement fiduciaries (including pension 
plans), investment advisers registered with the SEC, broker-dealers and 
other financial intermediaries (subject to federal securities laws), 
asset managers that are not registered with the SEC, and non-profit 
asset owners. Trustee boards and investment committees should 
demonstrate the consideration of climate and ESG impacts in the 
investment process and through the investment policy. DOL should (1) 
issue guidance that explicitly calls out climate factors as 
``pecuniary'' and therefore important considerations for ERISA 
fiduciaries and (2) issue a rule to clarify that climate factors are 
material and require ERISA plan fiduciaries adopt and implement 
sustainable investment policies. FINRA should enact reforms to the KYC 
rules to include seeking information about customer ESG-related 
preferences. The SEC should at a minimum (1) implement a rule under 
Section 203(c)1(C) under the Investment Advisers Act of 1940 requiring 
the Form ADV to require investment advisers to adopt and implement 
sustainable investment policies that incorporate climate risk and 
impact and (2) implement a rule under the Investment Company Act to 
require a fund to disclose on its prospectus and statement of 
additional information how the fund identifies, assesses, and addresses 
key climate issues, votes and otherwise engages with companies of 
portfolio securities consistent with sustainable investment policies, 
and has been audited for compliance with the policies.
Unlocking Consumer Finance
    Demand deposits are a bedrock of the financial system. Banks 
leverage consumer deposits to make loans and purchase assets; these 
accounts also create a customer relationship that results in fees for 
bank services and other product sales such as credit cards and auto 
loans. Domestic demand deposits in FDIC-insured banks and savings 
institutions are roughly at $15 trillion.\54\ If only 1.7 percent of 
these deposits were mobilized annually for climate solutions, the 
nation would surpass the additional investment amount needed to reach 
net zero by 2050 and avert a climate-induced financial crisis. Only 1.7 
percent of capital sitting in our everyday bank accounts.
    Unfortunately, it is currently cumbersome for consumers to align 
their deposits with a people and planet-friendly economy. Opening a new 
account and closing an old account is ``rarely easy and is usually 
hard.''\55\
    Switching bank accounts should be as easy as switching broker 
dealers and telephone providers. U.S. consumers now own their phone 
numbers, allowing them to easily choose a provider that suits their 
needs. This was enabled by the 1996 Telecommunications Act that 
required all carriers to offer mobile number portability (MNP). MNP 
allows consumers to contact a new carrier, who then transfers the 
account and service by contacting the consumer's current carrier. After 
receiving consumer complaints about transferring brokerage accounts, 
FINRA helped establish the Automated Customer Account Transfer Service; 
implemented in 2006, this allows consumers to transfer accounts and 
common assets such as cash or stocks from one broker-dealer to another, 
usually within a week.\56\
    Allowing retail and institutional consumers to own their bank 
account number and developing a system that allows for seamless 
switching would also enable consumers to have full rights and choice. 
There is international precedent and best practice for government 
enabling consumer switching. The United Kingdom implemented the Current 
Account Switch Service (CASS) in 2013 to provide seamless and quick 
switches in current accounts.\57\ The current barriers to switching 
accounts include the following processes: 1) needing to gather several 
pieces of information that one may not immediately have, such as the 
login details for current accounts and a driver's license number 2) the 
tediousness of needing to input information in poorly designed print or 
online forms, 3) the multiplicity of needing to switch direct deposit, 
linked cards, linked apps, and auto-pay, and 4) the lack of incentive 
or deadline to finish the process.\58\
    With 93 percent of households in the U.S. having a bank account and 
7 in 10 supporting government action to solve climate change,\59\ 
democratizing the ability to switch to climate-friendly bank accounts 
is a policy imperative. There is a growing movement of depository 
institutions, such as those listed in the Bank for Good campaign,\60\ 
that are limiting their exposure to climate risk and supporting the 
real economy in clean energy lending. Numerous examples of consumer 
behavior leading to significant market shifts include hundreds of 
millions moved to Black owned banks and Bank of America and other banks 
announcing that they would no longer charge a monthly fee for debit 
card holders after intense consumer pushback.\61\
    In order to enhance consumer choice in banking, policymakers can 
enact a number of changes, including: 1) reducing transactions costs 
through account portability rules, 2) mandating transparency for 
consumers around a bank's ESG practices, including the carbon footprint 
of loans and investments, and 3) lowering costs associated with closing 
and switching accounts. For the third change, the CFPB could set 
standards for lenders and third-party platforms that facilitate 
switching accounts, including eliminating the need to hold funds in two 
accounts at the same time.\62\
Conclusion
    All sectors of the economy will be impacted by climate change if 
the financial system does not work for the low carbon transition. These 
impacts will be especially acute in energy, transportation, and 
agriculture across the United States.\63\ Climate change, if left 
unabated, is expected to transform the regions of the U.S. in some of 
the following ways:

    West and Northwest: changed precipitation patterns 
        (including drought) and snow pack, increased risk of wildfires.

    Great Plains and the Midwest: increased frequency and 
        severity of flooding and drought.

    Northeast and Mid-Atlantic: increased storms and sea level 
        rise.

    South and Southwest: decreased precipitation levels, 
        leading to less water resources for agriculture, industry and 
        households.

    Southeast: warmer temperatures with more extreme heat 
        waves, increased sea level rise, increased hurricane intensity 
        and associated impacts to coastlines.

    Hawaii: increased sea level rise, loss of coral reefs, and 
        increased drought.

    Puerto Rico: increased sea level rise, loss of coral reefs, 
        increased frequency and intensity of hurricanes.

    Alaska: declined sea ice, earlier breakup of river ice in 
        the Spring, and thawing of permafrost.

    In order to avert economic disaster, the financial system must 
incorporate climate risk and impact into the market rules. The 
following changes will enable the system to finance less of the GHG 
emitting activities and more of the GHG reducing activities, all while 
supporting millions of new well-paid jobs that do not harm communities 
and help build wealth: mandating annual carbon accounting for financial 
institutions and reduction targets to reach net zero, providing patient 
capital to community-focused lenders to scale climate-friendly loans, 
adjusting capital requirements and risk weights for banks based on 
carbon emissions, implementing a climate-friendly grading system for 
SIFIs modeled after the CRA, and mandating the incorporation of ESG, 
including climate impact, into investment management.
[GRAPHICS NOT AVAILABLE IN TIFF FORMAT]

                 PREPARED STATEMENT OF JOHN H. COCHRANE
         Senior Fellow, Hoover Institution, Stanford University
                             March 18, 2021
    Chairman Brown, Ranking Member Toomey, and Members of the 
Committee: Thank you for the opportunity to testify today.
    I am John Cochrane. I am an economist, specializing in finance and 
monetary policy. My comments do not reflect the views of my employer or 
any institution with which I am affiliated.
    Climate change is an important challenge. But climate change poses 
no measurable risk to the financial system. This emperor has no 
clothes. ``Risk'' means unforeseen events. We know exactly where the 
climate is going over the horizon that financial regulation can 
contemplate. Weather is risky, but even the biggest floods, hurricanes, 
and heat waves have essentially no impact on our financial system.
    Moreover, the financial system is only at risk when banks as a 
whole lose so much, and so suddenly, that they blow through their 
reserves and capital, and a run on their short-term debt erupts. That 
climate may cause a sudden, unexpected and enormous economic effect, in 
the next decade, which could endanger the financial system, is an even 
more fantastic fantasy.
    Sure, we don't know what will happen in 100 years. But banks did 
not fail in 2008 because they bet on radios not TV in the 1920s. Banks 
failed over mortgage investments made in 2006. Trouble in 2100 will 
come from investments made in 2095. Financial regulation does not and 
cannot pretend to look past 5 years or so, and there is just no climate 
risk to the financial system at this horizon.
    Sure, a switch to renewables might lower oil company profits. Oil 
stockholders may lose money. But ``risk'' to the ``financial system'' 
cannot mean that nobody ever loses any money! Tesla could not have been 
built if people could not take ``risks.'' Yes, we are in a transition 
to a decarbonized economy, but the transitions from horses to cars, and 
from trains to planes, from typewriters to computers did not cause even 
blips in the financial system. Companies and industries come and go all 
the time.
    So why is there a push for regulators to force financial firms to 
``disclose'' absurdly fictitious ``climate risks,'' and change 
investments to avoid them? These proposals aim simply to defund the 
fossil fuel industry before alternatives are in place, and to steer 
funds to fashionable but unprofitable investments and away from 
unfashionable ones, by regulatory subterfuge rather than above-board 
legislation or transparent environmental agency rulemaking. This goal 
isn't a secret. For example, The Network of Central Banks and 
Supervisors for Greening the Financial System (NGFS), which the Federal 
Reserve recently joined, \1\ states plainly its goal is to ``mobilize 
mainstream finance to support the transition toward a sustainable 
economy.'' \2\
---------------------------------------------------------------------------
     \1\ https://www.federalreserve.gov/newsevents/pressreleases/
bcreg20201215a.htm
     \2\ https://www.ngfs.net/en
---------------------------------------------------------------------------
    But financial regulators are not allowed to ``mobilize'' the 
financial system, to choose projects they like and de-fund those they 
disfavor. Thus regulators must pretend that they are dispassionately 
finding ``risks'' to the financial system, and oh, just happen to 
stumble on climate.
    The climate focus proves the dishonesty. There are plenty of 
genuine risks to the financial system that our regulators largely 
ignore. Imagine a new pandemic, one that kills 10 percent not less than 
1 percent, and that lasts years with no vaccine. Suppose China invades 
Taiwan, or a nuclear weapon goes off in the Middle East. Another 
financial collapse can come. Imagine a global sovereign debt crisis. 
Suppose that the US Treasury runs out of room to borrow, is downgraded 
or defaults, and financial institutions no longer accept Treasury 
collateral. Imagine a massive cyberattack--all the accounts at Citibank 
are wiped out by North Korean hackers, and people rush for cash 
everywhere. These would indeed be financial system catastrophes. Yet of 
all of these large, obvious and quite plausible risks, our financial 
regulators want to focus on just one, a fictitious climate ``risk.'' 
Why? Obviously, the end justifies the means.
    Some advocates are a bit more honest: They recognize there is no 
financial risk due to climate itself, but climate regulation could come 
along and ``strand'' assets or hurt companies. The Godfather would be 
proud: Nice business you've got there, it would be a shame if something 
should happen to it. But think about it. This view posits that our 
environmental regulators are so bone-headed, so ignorant of basic cost-
benefit analysis, that they might suddenly and dramatically not just 
wipe out industries and millions of jobs, but do it in a way that 
causes colossal bank failures like 2008. And if we go down this path, 
here too, why just climate-related risk? There is lots of political and 
regulatory risk. Regulate and disclose tech exposure, in case the FTC 
breaks up big companies. Regulate steel exposure, always on the edge of 
tariffs one way or another. Uber could be outlawed by labor legislation 
tomorrow. An honest list of all the ways Congress or the agencies might 
plausibly destroy industries would make good reading. But we're not 
doing that, are we? The reason is obvious.
    Climate is really important. Climate is too important to let 
financial regulators play with it, inspired by what's fashionable at 
Davos cocktail parties. Climate needs clear-headed, science-based, 
steady, and transparently-enacted policy, with explicit cost-benefit 
analysis. Underhandedly funding and defunding financial regulators' 
momentary enthusiasms will repeat corn ethanol, switchgrass, an 
absurdly expensive rail line from Merced to Bakersfield that comes 
online just as all cars and trucks are electric, and other 
counterproductive feel-good policies. The US leads the world in carbon 
reduction today because of natural gas produced by fracking, which no 
regulator ``mobilized.'' Climate answers may include nuclear power, 
geoengineering, carbon capture and storage, hydrogen fuel cells, 
genetically engineered foods, zoning reform, a carbon tax, and other 
approaches, which financial regulators will never even envision let 
alone implement.
    Financial regulation is really important. Financial regulation is 
too important to be eviscerated on the altar of de-funding fossil fuel 
and subsidies to pet projects. Once regulators cook up fantasy 
``climate risks,'' the books remain cooked, and financial regulation 
loses whatever any ability to perceive and to offset genuine risks. 
Once financial regulators demand funding of today's fashionable green 
projects, the political allocation of credit will expand.
    Financial regulation and the financial system are in peril, and not 
because of climate. Contemplate the abject failure sitting in front of 
us. Despite 12 years of Dodd-Frank regulation, stress tests, and armies 
of embedded regulators, despite centuries of experience, ARS, H1N1, 
Ebola, Aids, 1918, and many federal pandemic plans, financial 
regulators failed to consider that a pandemic might come along. We made 
it through the last year by one more massive bail-out, not by 
regulatory prescience. The financial system remains far too leveraged 
and far too reliant on an even larger bailout that may not come in the 
next crisis. And now they want to soothsay climate?
    We need to get financial regulation back to its job: making sure 
that run-prone financial institutions have adequate capital to 
withstand all sorts of shocks, which none of us, not least the 
regulators, can pretend to foresee. It's boring. You don't get invited 
to Davos to talk about it. Industry hates being told to get more 
capital. But that's its job and there is plenty to do.
    Don't let the EPA regulate banks, and don't let our financial 
regulators dream up climate policy. You will get bad climate policy, 
and an even more fragile and sclerotic financial system if you do.
                 PREPARED STATEMENT OF BENJAMIN ZYCHER
            Resident Scholar, American Enterprise Institute
                             March 18, 2021
    Thank you, Chairman Brown and Ranking Member Toomey, for this 
opportunity to offer my views on the topic of the financial system and 
anthropogenic climate change, one now receiving substantial attention 
from policymakers and many interested observers. The Statement below 
makes a number of observations that I hope will prove of interest to 
this Committee. I begin with a summary of my arguments, and then 
proceed to discuss them in more detail in the ensuing sections:

  1.  Climate Uncertainties and Choices Among Crucial Assumptions.

  2.  The Evidence on Climate Phenomena and the Effects of Climate 
        Policies in the EPA Climate Model.

  3.  Observations on the Materiality of Climate ``Risks.''

  4.  Additional Observations and Conclusions.
Summary
    Neither the Federal Reserve or any other bank regulator, 
        nor banks or other financial institutions, are in a position to 
        evaluate climate phenomena, whether ongoing or prospective, 
        with respect to which the scientific uncertainties are vastly 
        greater than commonly asserted.

    The range of alternative assumptions about central 
        parameters is too great to yield clear implications for the 
        climate ``risks'' attendant upon the allocation of financial 
        capital among economic sectors.

    Those central parameters include the choices among climate 
        models, the assumed sensitivity of the climate system to 
        increases in the atmospheric concentration of greenhouse gases 
        (GHG), the assumed future increase in that GHG concentration 
        through, say, 2100, and the analytic assumptions underlying 
        calculations of the effects of aerosol emissions on cloud 
        formation, about which surprisingly little is known. That short 
        list is far from exhaustive.

    If the Federal Reserve and the financial institutions opt 
        to use the same (or similar) sets of assumptions about central 
        parameters, a very real danger would arise of more-or-less 
        homogeneous predictions inconsistent with historical, ongoing, 
        and prospective climate phenomena. If the Federal Reserve and 
        the financial institutions opt to use sets of assumptions that 
        differ in important dimensions, the ensuing predictions about 
        future climate phenomena (risks) would vary substantially, 
        yielding very large uncertainties in terms of policy 
        implications.

    It is reasonable to hypothesize that financial institutions 
        will have powerful incentives to undertake climate analysis 
        driven not by the actual evidence and the peer-reviewed 
        literature on climate phenomena. Instead, they will be driven 
        to undertake such analysis, whether in response to regulatory 
        directives or to political pressures, under assumptions and 
        methodologies insulating them from adverse regulatory actions 
        and litigation threats.

    It is reasonable to hypothesize also that the aggregate 
        benefits (that is, positive ``risks'') of increasing GHG 
        concentrations, as reported by the National Oceanic and 
        Atmospheric Administration and in the peer-reviewed literature, 
        will be excluded from such analytic efforts.

    It is reasonable to hypothesize further that such analyses 
        will exclude the risks of climate policies, prominent among 
        which are the large and adverse implications of artificial 
        increases in energy costs. Such policy risks are likely to be 
        greater when implemented by bureaucracies insulated from 
        democratic accountability.

    Anthropogenic climate change is ``real'' in that increasing 
        atmospheric concentrations of GHG have yielded effects that are 
        detectable. But they are much smaller than commonly asserted; 
        and there is no evidence in support of the ubiquitous 
        assertions of a climate ``crisis,'' whether ongoing or looming, 
        and no evidence in support of the even more extreme 
        ``existential threat'' argument. Moreover, the available 
        analysis suggests that the financial risks of anthropogenic 
        climate change in the aggregate are much smaller than many 
        assert.

    The mainstream climate models have a poor track record in 
        terms of predicting the actual temperature trend of recent 
        decades, having consistently overstated that trend by a factor 
        of over two.

    Application of the Environmental Protection Agency climate 
        model suggests strongly that climate policies, whether 
        implemented by the U.S. Government alone or as an international 
        cooperative policy, would have temperature effects by 2100 that 
        would be virtually undetectable or very small. Such policies 
        cannot satisfy any plausible benefit/cost test.

    Because the perceived ``climate risks'' confronting the 
        financial sector are dependent upon crucial choices among 
        alternative assumptions, the evaluation of such ``risks'' would 
        be largely arbitrary given that the ``correct'' assumptions are 
        very far from obvious. This means that a requirement, whether 
        formal or informal, that climate ``risks'' be incorporated into 
        the business decisions of financial institutions would weaken 
        the materiality standard for disclosures by those institutions. 
        ``Materiality'' always has meant the disclosure of information 
        directly relevant to the financial performance of the bank or 
        other institution. When ``risk'' analysis becomes an arbitrary 
        function of choices among assumptions complex, opaque, and far 
        from obvious, the traditional materiality standard inexorably 
        will be diluted and rendered far less useful for the investment 
        and financial markets, an outcome diametrically at odds with 
        the ostensible objectives of those advocating the evaluation of 
        climate ``risks.'' Moreover, the ``risks'' of anthropogenic 
        climate change are far from the only such mass-geography 
        ``risks.'' A bias toward focusing only on climate ``risks'' 
        would distort the allocation of capital.

    Because the uncertainties attendant upon the future effects 
        of increasing atmospheric concentrations of GHG are so great, a 
        top-down policy approach for the evaluation of any attendant 
        ``risks'' is itself very risky. A wiser approach would entail 
        allowing market forces to make such ``risk'' determinations in 
        a bottom-up fashion, thus avoiding an obvious politicization of 
        the allocation of capital.

    Proposals that the Federal Reserve enforce a mandate that 
        financial institutions evaluate climate ``risks'' represent a 
        blatant effort to distort the allocation of capital away from 
        economic sectors disfavored by certain political interest 
        groups pursuing ideological agendas. This would represent the 
        return of Operation Choke Point, a past attempt to politicize 
        access to credit, one deeply corrosive of our legal and 
        constitutional institutions.

    Protection of those institutions is consistent only with 
        formal policymaking by the Congress through enactment of 
        legislation, rather than with powerful pressures, whether 
        formal or informal, exerted by the Federal Reserve or other 
        regulatory agencies. This institutional protection would 
        preserve the traditional roles of the private sector and of the 
        government, respectively, as part of the larger permanent 
        objectives of maximizing the productivity of resource use under 
        free market competition, and preserving the political 
        accountability of the policymaking process under the 
        institutions of democratic decisionmaking as constrained by the 
        constitution.
Climate Uncertainties and Choices Among Crucial Assumptions
    Notwithstanding ubiquitous assertions that climate science is 
``settled,'' that a crisis is upon us or looming large, and that 
government policies must address the ``existential threat'' posed by 
anthropogenic climate change, in reality the uncertainties attendant 
upon the prospective effects of increasing atmospheric concentrations 
of greenhouse gases (GHG) are very substantial. Moreover, no evidence 
supports the ``crisis'' narrative, as discussed below. These realities 
are illustrated by the ranges of various estimates published by the 
Intergovernmental Panel on Climate Change (IPCC) in its most recent 
Assessment Report, by the wide range of temperature paths projected by 
the mainstream climate models, and by the scientific literature more 
generally. \1\
---------------------------------------------------------------------------
     \1\ See, e.g., Figure 2.5 in the IPCC Fifth Assessment Report 
(2013), on alternative paths for future temperature changes, at https:/
/www.ipcc.ch/report/ar5/syr/synthesis-report/. On the wide range of 
temperature projections yielded by the mainstream climate models, see 
Figure 2 in the testimony of John R. Christy before the U.S. House 
Committee on Science, Space, and Technology, March 29, 2017, at https:/
/science.house.gov/imo/media/doc/Christy%20Testimony-1.pdf?1. On the 
general state of scientific uncertainty in the context of climate 
phenomena, see e.g., Judith Curry, ``Uncertainty About the Climate 
Uncertainty Monster,'' Climate Etc., May 19, 2017, at https://
judithcurry.com/2017/05/19/uncertainty-about-the-climate-uncertainty-
monster/.
---------------------------------------------------------------------------
    The evaluation of climate ``risks'' to the financial system would 
require choices among the available climate models, choices among 
alternative assumptions about the path of future atmospheric 
concentrations of GHG, choices among assumptions about the effect of 
increasing GHG concentrations upon the climate system, that is, the 
``sensitivity'' of the climate system, and deeply problematic 
assumptions about the effects of aerosol emissions on cloud formation, 
about which little is known. \2\
---------------------------------------------------------------------------
     \2\ See, e.g., Judith Curry, ``The Cloud-Climate Conundrum'', 
Climate Etc., June 2, 2016, at https://judithcurry.com/2016/06/02/the-
cloud-climate-conundrum/.
---------------------------------------------------------------------------
    Let us note that the mainstream climate models have found it very 
difficult to predict the historical and current climate record; as an 
example, the models have been unable to explain the warming observed 
from 1910-1945. \3\ That period of warming cannot have been the result 
of increased atmospheric concentrations of GHG, in that such 
concentrations had increased only from about 278 ppm in 1750 to about 
295 ppm by 1910. \4\ Another example: Every climate model predicts that 
increasing atmospheric concentrations of GHG should result in an 
enhanced heating effect in the mid- and upper troposphere over the 
tropics. The satellites have been unable to find that effect. \5\ In 
the latest iteration of the suite of climate models, to be applied in 
the next IPCC Assessment report, the average predicted tropospheric 
temperature increase for 1979-2019 is 0.40 degrees C per decade. The 
actual record as measured by the satellites: 0.17 degrees C per decade. 
\6\ The climate models on average have overstated the temperature 
record by a factor of more than two.
---------------------------------------------------------------------------
     \3\ See the HadCRUT5 reconstructions of temperature anomalies at 
https://crudata.uea.ac.uk/cru/data/temperature/. Interestingly enough, 
the Russian climate models from the Institute for Numerical Mathematics 
(models INM-CM4 and INM-CM4.8) do the best job of predicting the past 
and the present. See http://www.glisaclimate.org/node/2220 and https://
www.researchgate.net/publication/329748540-Simulation-of-the-modern-
climate-using-the-INM-CM48-climate-model.
     \4\ See the NOAA reconstruction of carbon dioxide emissions and 
concentrations for 1750-2019 at https://www.climate.gov/sites/default/
files/CO2-emissions-vs-concentrations-1751-2019-lrg.gif.
     \5\ The tropics for the most part are water, and emissions of 
additional GHG would warm the earth slightly, resulting in an increase 
in ocean evaporation. In the climate models, as the water vapor rises 
into the mid troposphere, it condenses, releasing heat. This seems 
straightforward, but efforts to demonstrate this phenomenon with 
satellite measurements have proven very difficult. See Ross McKitrick 
and John R. Christy, ``Pervasive Warming Bias in CMIP6 Tropospheric 
Layers,'' Earth and Space Science, Vol. 7, Issue 9 (September 2020), at 
https://agupubs.onlinelibrary.wiley.com/doi/10.1029/2020EA001281; and 
Ross McKitrick, ``New Confirmation That Climate Models Overstate 
Atmospheric Warming'', Climate Etc., August 25, 2020, at https://
judithcurry.com/2020/08/25/new-confirmation-that-climate-models-
overstate-atmospheric-warming/.
     \6\ See the Coupled Model Intercomparison Project, Phase 6, at 
https://pcmdi.llnl.gov/CMIP6/. See also, e.g., the recent presentation 
by Professor John R. Christy at https://www.youtube.com/
watch?v=D2Cd4MLUoN0.
---------------------------------------------------------------------------
    Consider only the effect of varying assumptions about the future 
path of atmospheric GHG concentrations. IPCC in the latest (2013) 
Assessment Report uses four such alternative paths: Representative 
Concentrations Pathways 2.6, 4.5, 6, and 8.5. \7\ The following table 
illustrates the range of temperature effects (anomalies) by 2100 under 
the four RCPs.
---------------------------------------------------------------------------
     \7\ The figures (2.6, etc.) are not temperature effects; they are 
theoretical calculations of ``radiative forcings'' in watts per square 
meter. For an introduction, see G.P. Wayne, ``The Beginner's Guide to 
Representative Concentration Pathways'', Skeptical Science, August 
2013, at https://skepticalscience.com/docs/RCP-Guide.pdf.
[GRAPHIC NOT AVAILABLE IN TIFF FORMAT]

    Neither the Federal Reserve or any other bank regulator, nor banks 
or other financial institutions, are in a position to evaluate the 
strengths and weaknesses of alternative RCP assumptions, or of the 
other crucial parameters underlying climate projections in the context 
of GHG emissions. \8\ The IPCC in the 2013 Assessment Report provides a 
range of estimates for the equilibrium sensitivity of the climate 
system, from 1.5 degrees to 4.5 degrees, with a mean of 3 degrees. \9\ 
Many of the more extreme or ``alarmist'' assertions of the effects of 
anthropogenic climate change assume RCP8.5 and a climate sensitivity of 
4.5 degrees (or even higher). The numerous estimates reported in the 
peer-reviewed literature do not support that assumption, instead 
supporting an assumption of 2 degrees or even less; the range estimated 
from the actual data is 1.5 to 2.3 degrees C. \10\
---------------------------------------------------------------------------
     \8\ Note that RCP8.5 is a popular assumption among those 
advocating strong climate policies, but it is a scenario essentially 
impossible. Under RCP8.5, atmospheric concentrations of GHG rise at 
almost 12 parts per million (ppm) through 2100 as an annual average; 
the average for 1985-2019 was about 1.9 ppm, and the single largest 
increase was about 3 ppm in 2016. See the data reported by NOAA at 
https://www.esrl.noaa.gov/gmd/ccgg/trends/global.html. See Kevin 
Murphy, ``Reassessing the RCPs,'' Climate Etc., January 28, 2019, at 
https://judithcurry.com/2019/01/28/reassessing-the-rcps/; and Judith 
Curry, ``Is RCP8.5 An Impossible Scenario?'', Climate Etc., November 
24, 2018, at https://judithcurry.com/2018/11/24/is-rcp8-5-an-
impossible-scenario/.
     \9\ The equilibrium sensitivity of the climate system is the 
temperature increase that would result from a doubling of atmospheric 
concentrations of GHG, after the climate system were to ``finalize'' 
all attendant adjustments.
     \10\ See Patrick J. Michaels and Paul C. Knappenberger, 
Lukewarming: The New Climate Science That Changes Everything, 
Washington, DC: Cato Institute, 2016; and the recent presentation by 
Professor John R. Christy at https://www.youtube.com/
watch?v=D2Cd4MLUoN0.
---------------------------------------------------------------------------
    Again: Neither the Federal Reserve or any other bank regulator, nor 
banks or other financial institutions, are in a position to sort 
through such enormous complexities; government agencies and 
international bodies wholly dedicated to doing so find the task 
daunting. Instead, the Federal Reserve and financial institutions will 
be driven to adopt assumptions (or to retain consultants who will do 
so) minimizing the degree to which their analyses might subject them to 
political attacks, adverse regulatory actions, and litigation. This is 
very different from an objective effort to evaluate climate phenomena 
and a reasonable range of prospective effects of increasing GHG 
concentrations, that is, climate ``risks.''
    Instead, for example, they will have powerful incentives to use the 
Environmental Protection Agency climate model, used by most federal 
agencies to evaluate climate trends and the effects of climate 
policies; since that is the U.S. Government model, it would be 
difficult to attack a financial institution for choosing it. \11\ For 
the earlier suite of climate models (CMIP-5), the EPA model provided 
predictions close to the average of those models under a given set of 
underlying assumptions, equilibrium climate sensitivity in particular. 
For the new suite (CMIP-6), the EPA model provides predictions cooler 
than the average of those models, not because the EPA model now is 
providing predictions more consistent with the historical evidence, but 
because the CMIP-6 models have incorporated a range of climate 
sensitivity assumptions and estimates higher on average than those in 
the CMIP-5 iteration. That range of climate sensitivity values in CMIP-
6 also is wider than that in CMIP-5, meaning that the uncertainty of 
the climate models is increasing. \12\
---------------------------------------------------------------------------
     \11\ This is the Model for the Assessment of Greenhouse Gas 
Induced Climate Change (MAGICC), at www.magic.org.
     \12\ Private communication with Professor John R. Christy, March 
14, 2021. See CMIP-5 at https://pcmdi.llnl.gov/mips/cmip5/; and CMIP-6 
at https://pcmdi.llnl.gov/CMIP6/.
---------------------------------------------------------------------------
    Again, the Federal Reserve and the financial institutions will have 
powerful incentives to choose among assumptions on future emissions and 
atmospheric concentrations, climate sensitivity, and other crucial 
parameters so as to insulate themselves from political attack, adverse 
regulatory actions, and litigation. They thus will be led toward 
analytic homogeneity, yielding a very real danger of an artificial 
``consensus'' among financial institutions regardless of the actual 
evidence, and perhaps largely inconsistent with it. Any such consensus 
would be an artifact of the political pressures to which the financial 
institutions would be subjected; it would have nothing to do with 
``science.''
    If, implausibly, the Federal Reserve and the financial institutions 
were to opt to use models and/or sets of assumptions that differ in 
important dimensions, the ensuing predictions about future climate 
phenomena (risks) would vary substantially or hugely, yielding very 
large uncertainties in terms of policy implications. What would the 
Federal Reserve do under that condition, how would financial 
institutions respond, and--again--what would such decisions have to do 
with ``science''?
    Those political pressures will weigh against consideration of the 
benefits of increasing atmospheric concentrations of GHG, as reported 
by the National Oceanic and Atmospheric Administration (NOAA), and in 
the peer-reviewed literature. Examples are planetary greening, 
increased agricultural productivity, increased water use efficiency by 
plants, and reduced mortality from cold. \13\ Nor will such analysis 
include the possible adverse impacts of government climate policies, 
which as a core imperative must have the effect of increasing energy 
costs artificially, notwithstanding common assertions that alternative 
energy sources are competitive in terms of costs. \14\ More narrowly, 
government policies that lead financial institutions to incorporate 
climate ``risks'' into their decisions on lending and other parameters 
are likely to yield important distortions in capital markets, one of 
which is a weighting of climate ``risks'' above those posed by other 
important natural phenomena.
---------------------------------------------------------------------------
     \13\ On the carbon dioxide ``greening'' effect see NOAA at https:/
/www.nasa.gov/feature/goddard/2016/carbon-dioxide-fertilization-
greening-earth. On the agricultural productivity effects, see, e.g., 
Goudriaan and Unsworth at https://acsess.onlinelibrary.wiley.com/doi/
abs/10.2134/asaspecpub53.c8. On water use efficiency by plants, see, 
e.g., http://www.co2science.org/subject/w/summaries/wateruse.php. On 
the beneficial impacts of moderate warming on mortality, see https://
www.thelancet.com/journals/lancet/article/PIIS0140-6736(14)62114-0/
fulltext.
     \14\ See Benjamin Zycher, The Green New Deal: Economics and Policy 
Analytics, American Enterprise Institute, 2019, at http://www.aei.org/
wp-content/uploads/2019/04/RPT-The-Green-New-Deal-5.5x8.5-
FINAL.pdf?x91208.
---------------------------------------------------------------------------
The Evidence on Climate Phenomena and the Effects of Climate Policies 
        in the EPA Climate Model
    The available body of evidence does not support the ubiquitous 
assertions that a climate ``crisis'' is upon us or looming large. This 
means in the context of this hearing that the asserted climate 
``risks'' threatening the U.S. financial system are far less obvious 
than often assumed.
    That anthropogenic climate change is ``real''--that increasing GHG 
concentrations are having detectable effects--is incontrovertible, but 
that does not tell us the magnitude of the observable impacts, which 
must be measured empirically. Temperatures are rising, but as the 
Little Ice Age ended no later than 1850, it is not easy to separate 
natural from anthropogenic effects on temperatures and other climate 
phenomena. \15\ The latest research in the peer-reviewed literature 
suggests that mankind is responsible for about half a degree of the 
global temperature increase of about 1.5-1.7 degrees C of global 
warming observed since 1850. \16\
---------------------------------------------------------------------------
     \15\ On the surface (land/ocean) temperature record, see UK Met 
Office, Hadley Centre/University of East Anglia Climatic Research Unit, 
``Tim Osborn: HadCRUT4 Global Temperature Graphs,'' https://
crudata.uea.ac.uk/timo/diag/tempdiag.htm. On the Little Ice Age, see 
Michael E. Mann, ``Little Ice Age,'' in Encyclopedia of Global 
Environmental Change, Volume 1: The Earth System: Physical and Chemical 
Dimensions of Global Environmental Change, ed. Michael C. MacCracken, 
John S. Perry and Ted Munn (Chichester, England: John Wiley & Sons, 
2002), http://www.meteo.psu.edu/holocene/public-html/shared/articles/
littleiceage.pdf.
     \16\ See, for example, Ross McKitrick and John Christy, ``A Test 
of the Tropical 200- to 300 hPa Warming Rate in Climate Models''; 
Nicholas Lewis and Judith Curry, ``The Impact of Recent Forcing and 
Ocean Heat Uptake Data on Estimates of Climate Sensitivity,'' Journal 
of Climate 31 (August 2018): 6051-71, https://journals.ametsoc.org/doi/
pdf/10.1175/JCLI-D-17-0667.1; and John R. Christy and Richard McNider, 
``Satellite Bulk Tropospheric Temperatures as a Metric for Climate 
Sensitivity,'' Asia-Pacific Journal of Atmospheric Sciences 53 (2017): 
511-18, https://link.springer.com/article/10.1007/s13143-017-0070-z. 
For a chart summarizing the recent empirical estimates of equilibrium 
climate sensitivity as reported in the peer-reviewed literature, see 
Patrick J. Michaels and Paul C. Knappenberger, ``The Collection of 
Evidence for a Low Climate Sensitivity Continues to Grow,'' Cato 
Institute, September 25, 2014, https://www.cato.org/blog/collection-
evidence-low-climate-sensitivity-continues-grow.
---------------------------------------------------------------------------
    The ``crisis'' assertions are unsupported by the evidence reported 
in the peer-reviewed, official, or scientific literature. There is 
little trend in the number of ``hot'' days for 1895-2017; 11 of the 12 
years with the highest number of such days occurred before 1960. \17\ 
NOAA has maintained since 2005 the U.S. Climate Reference Network, 
comprising 114 meticulously maintained temperature stations spaced more 
or less uniformly across the lower 48 States, 21 stations in Alaska, 
and two stations in Hawaii. \18\ They are placed to avoid heat island 
effects and other such distortions as much as possible; the reported 
data show no trend over the available 2005-20 reporting period. \19\ A 
reconstruction of global temperatures over the past one million years, 
using data from ice sheet formations, shows that there is nothing 
unusual about the current warm period. \20\
---------------------------------------------------------------------------
     \17\ For the reconstruction of the NASA data, see John R. Christy, 
``Average per Station (1114 USHCN Stations) 1895-2017: Number of Days 
Daily Maximum Temperature Above 100 F and 105 F,'' drroyspencer.com, 
http://www.drroyspencer.com/wp-content/uploads/US-extreme-high-
temperatures-1895-2017.jpg.
     \18\ For the Climate Reference Network program description, see 
National Centers for Environmental Information, ``U.S. Climate 
Reference Network,'' https://www.ncdc.noaa.gov/crn/.
     \19\ For a visualization of a prototypical station, see Willis 
Eschenbach, ``NOAA's USCRN Revisited-No Significant Warming in the USA 
in 12 Years,'' Watts Up with That?, November 8, 2017, https://
wattsupwiththat.com/2017/11/08/the-uscrn-revisited/. For the monthly 
data and charts reported by the National Oceanic and Atmospheric 
Administration (NOAA), see National Oceanic and Atmospheric 
Administration, ``National Temperature Index,'' https://
www.ncdc.noaa.gov/temp-and-precip/national-temperature-index/time-
series?datasets%5B%5D=uscrn&parameter=anom-tavg&time-
scale=p12&begyear=2005&endyear=2020&month=8.
     \20\ See R. Bintanja and R.S.W. van de Wal, ``North American Ice-
Sheet Dynamics and the Onset of 100,000-Year Glacial Cycles,'' Nature 
454, no. 7206 (August 14, 2008): 869-72, https://www.researchgate.net/
publication/23171740--Bintanja-R-van-de-Wal-R-S-W-North-American-ice-
sheet-dynamics-and-the-onset-of-100000-year-glacial-cycles-Nature-454-
869-872. NOAA published the underlying data at R. Bintanja and R. S. W. 
van de Wal, ``Global 3Ma Temperature, Sea Level, and Ice Volume 
Reconstructions,'' National Oceanic and Atmospheric Administration, 
August 14, 2008, https://www.ncdc.noaa.gov/paleo-search/study/11933. 
For a chart showing the temperature record over one million years, see 
Institute for Energy Research, ``Temperature Fluctuations over the Past 
Million Years,'' https://www.instituteforenergyresearch.org/wp-content/
uploads/2020/03/temperature-flucturations.png.
---------------------------------------------------------------------------
    Global mean sea level has been increasing at about 3.3 mm per year 
since satellite measurements began in 1992. The tidal-gauge data before 
then show annual increases of about 1.9 mm per year, but that 
comparison does not show an acceleration because the two datasets are 
not comparable. The tidal gauges do not measure sea levels per se; they 
measure the difference between sea levels and ``fixed'' points on land 
that in reality might not be fixed due to seismic activity, tectonic 
shifts, land settlement, etc. Accordingly, the data are unclear as to 
whether there is occurring an acceleration in sea level rise; it is 
reasonable to hypothesize that there has been such an acceleration 
simply because temperatures are rising, as noted above, and such 
increases should result in more melting ice and the thermal expansion 
of water. But because rising temperatures are the result of both 
natural and anthropogenic causes, we do not know the relative 
contributions of those causes to any such acceleration. \21\
---------------------------------------------------------------------------
     \21\ As a crude approximation, the data suggest that about two-
thirds of such sea level increases are due to ice melt, and one-third 
to thermal expansion of water. See Judith Curry, ``Sea Level and 
Climate Change,'' Climate Forecast Applications Network, November 25, 
2018, https://curryja.files.wordpress.com/2018/11/special-report-sea-
level-rise3.pdf. Curry cites research from Xianyao Chen and colleagues, 
the central finding of which is that ``global mean sea level rise 
increased from 2.2 plus/minus 0.3 mm/year in 1993 to 3.3 plus/minus 0.3 
mm/year in 2014.'' See Xianyao Chen et al., ``The Increasing Rate of 
Global Mean Sea-Level Rise During 1993-2014,'' Nature Climate Change 7 
(June 26, 2017): 492-95, https://www.nature.com/articles/nclimate3325. 
Whether the trend from a 21-year period can yield important inferences 
is a topic not to be addressed here. For a different empirical 
conclusion from the tidal gauge record, see J.R. Houston and R. G. 
Green, ``Sea-Level Acceleration Based on U.S. Tide Gauges and 
Extensions of Previous Global-Gauge Analyses,'' Journal of Coastal 
Research 27, no. 3 (May 2011): 409-17, https://meridian.allenpress.com/
jcr/article-abstract/27/3/409/28456/Sea-Level-Acceleration-Based-on-U-
S-Tide-Gauges?redirectedFrom=fulltext. For an example of temporary 
rapid sea-level rise in the 18th century, see W.R. Gehrels et al., ``A 
Preindustrial Sea-Level Rise Hotspot Along the Atlantic Coast of North 
America,'' Geophysical Research Letters 47 (2020), https://
agupubs.onlinelibrary.wiley.com/doi/epdf/10.1029/2019GL085814. For 
further reported evidence of an acceleration, see Hans-Otto Portner et 
al., Special Report on the Ocean and Cryosphere in a Changing Climate, 
Intergovernmental Panel on Climate Change, 2019, https://www.ipcc.ch/
srocc/.
---------------------------------------------------------------------------
    The Northern and Southern Hemisphere sea ice changes tell different 
stories; the arctic sea ice has been declining, while the Antarctic sea 
ice has been stable or growing. \22\ U.S. tornado activity shows either 
no trend or a downward trend since 1954. \23\ Tropical storms, 
hurricanes, and accumulated cyclone energy show little trend since 
satellite measurements began in the early 1970s. \24\ The number of 
U.S. wildfires shows no trend since 1985, and global acreage burned has 
declined over past decades. \25\ The Palmer Drought Severity index 
shows no trend since 1895. \26\ U.S. flooding over the past century is 
uncorrelated with increasing GHG concentrations. \27\ The available 
data do not support the ubiquitous assertions about the dire impacts of 
declining pH levels in the oceans. \28\ Global food availability and 
production have increased more or less monotonically over the past two 
decades on a per capita basis. \29\ The IPCC itself in the Fifth 
Assessment Report was deeply dubious about the various severe effects 
often asserted to be looming as impacts of anthropogenic warming. \30\
---------------------------------------------------------------------------
     \22\ See Patrick J. Michaels, ``Spinning Global Sea Ice,'' Cato 
Institute, February 12, 2015, https://www.cato.org/blog/spinning-
global-sea-ice. It appears to be the case that the Antarctic eastern 
ice sheet--about two-thirds of the continent--is growing, while the 
western ice sheet (and the peninsula) may be shrinking. No agreed 
explanation for this phenomenon is reported in the literature.
     \23\ For the historical data reported by the NOAA, see National 
Ocean and Atmospheric Administration, ``Historical Records and 
Trends,'' https://www.ncdc.noaa.gov/climate-information/extreme-events/
us-tornado-climatology/trends.
     \24\ For data on global tropical cyclone activity, see Ryan N. 
Maue, ``Global Tropical Cyclone Activity'', updated March 16, 2021, at 
http://climatlas.com/tropical/.
     \25\ For the reported U.S. wildfire data, see National Interagency 
Fire Center, ``Total Wildland Fires and Acres (1926-2019),'' https://
www.nifc.gov/fireInfo/fireInfo-stats-totalFires.html. On the decline in 
global area burned over past decades, see Stefan H. Doerr and Cristina 
Santin, ``Global Trends in Wildfire and Its Impacts: Perceptions Versus 
Realities in a Changing World,'' Philosophical Transactions of the 
Royal Society of London, Series B, Biological Sciences 371, no. 1696 
(2016), https://www.ncbi.nlm.nih.gov/pmc/articles/PMC4874420/pdf/
rstb20150345.pdf.
     \26\ See US Environmental Protection Agency, ``Climate Change 
Indicators: Drought,'' https://www.epa.gov/climate-indicators/climate-
change-indicators-drought; and US Department of Commerce, National 
Climatic Data Center, ``Divisional Data Select,'' https://
www7.ncdc.noaa.gov/CDO/CDODivisionalSelect.jsp.
     \27\ See R.M. Hirsch and K.R. Ryberg, ``Has the Magnitude of 
Floods Across the USA Changed with Global CO2 Levels?,'' Hydrological 
Sciences Journal 57, no. 1 (2012): 1-9, https://www.tandfonline.com/
doi/full/10.1080/02626667.2011.621895?scroll=top&needAccess=true&.
     \28\ See CO2 Science, ``Ocean Acidification Database,'' http://
www.co2science.org/data/acidification/results.php. See also Alan 
Longhurst, Doubt and Certainty in Climate Science, pp. 214-25, https://
curryja.files.wordpress.com/2015/09/longhurst-print.pdf.
     \29\ See Food and Agriculture Organization of the United Nations, 
World Food and Agriculture Statistical Pocketbook 2018, 2018, Charts 28 
and 46, http://www.fao.org/3/CA1796EN/ca1796en.pdf. See also Kevin D. 
Dayaratna, Ross McKitrick, and Patrick J. Michaels, ``Climate 
Sensitivity, Agricultural Productivity and the Social Cost of Carbon in 
FUND,'' Environmental Economics and Policy Studies 22 (2020): 433-48.
     \30\ Julie M. Arblaster et al., ``Long-Term Climate Change: 
Projections, Commitments and Irreversibility-Final Draft Underlying 
Scientific-Technical Assessment,'' in Working Group I Contribution to 
the IPCC Fifth Assessment Report (AR5), Climate Change 2013: The 
Physical Science Basis, September 23-26, 2013, p. 12-78, http://
www.climatechange2013.org/images/uploads/WGIAR5-WGI-12Doc2b-FinalDraft-
Chapter12.pdf.
---------------------------------------------------------------------------
    If we apply the Environmental Protection Agency climate model, 
under sensitivity assumptions higher than those reported in the recent 
peer-reviewed literature, net-zero U.S. GHG emissions effective 
immediately would yield a reduction in global temperatures of 0.104 
degrees C by 2100. That effect would be barely detectable given the 
standard deviation (about 0.11 degrees C) of the surface temperature 
record. \31\ The entire Paris agreement: about 0.17 degrees C. Net-zero 
emissions by the entire Organization for Economic Cooperation and 
Development: 0.21 degrees C. A 35 percent reduction in global GHG 
emissions implemented immediately and maintained strictly would reduce 
global temperatures in 2100 by about half a degree. \32\ Note that GHG 
emissions in 2020 fell by about 6.4 percent as a result of the COVID-19 
economic downturn. \33\ Can anyone believe that even larger GHG 
reductions are plausible politically? Is there a believable benefit/
cost model that would justify such policies?
---------------------------------------------------------------------------
     \31\ See https://agupubs.onlinelibrary.wiley.com/doi/pdf/10.1029/
1999JD900835.
     \32\ Author computations using MAGICC 5.3. The MAGICC model can be 
found at http://www.magicc.org/.
     \33\ See https://www.nature.com/articles/d41586-021-00090-3.
---------------------------------------------------------------------------
Observations on the Materiality of Climate ``Risks''
    It is clear that those in support of the proposition that banks and 
other financial institutions evaluate the ``risks'' of anthropogenic 
climate change to the financial system view such analyses as 
``material'' in terms of disclosures to investors. \34\ Several 
problems are attendant upon that premise, in substantial part for the 
reasons discussed above. Any such projections of climate phenomena and 
resulting ``risks'' to the financial system--far into the future--are 
very far from trivial methodologically. Which climate model(s) should 
financial institutions use? Which assumptions about future emissions, 
about the sensitivity of the climate system, about policies to be 
adopted internationally, about the climate effects of those policies, 
ad infinitum, should financial institutions incorporate into those 
models? Are those financial institutions--even very large ones--in a 
position to do such analysis in a credible fashion? If not, whom should 
they retain to do that analysis for them, and how should they evaluate 
the differences among the available alternative providers of such 
analyses?
---------------------------------------------------------------------------
     \34\ See the Federal Reserve Financial Accounting Manual for 
Federal Reserve Banks at https://www.federalreserve.gov/aboutthefed/
files/BSTfinaccountingmanual.pdf. The Securities and Exchange 
Commission final rule for materiality disclosure requirements for banks 
is at https://www.federalregister.gov/documents/2020/10/16/2020-20655/
update-of-statistical-disclosures-for-bank-and-savings-and-loan-
registrants.
---------------------------------------------------------------------------
    The reality is that a ``climate risk'' disclosure requirement would 
be deeply speculative, and the level of detail and the scientific 
sophistication that would be needed to satisfy such a requirement is 
staggering. Such ``disclosures'' and supporting analysis and 
documentation would take up thousands of pages, with references to 
thousands more, and the premise that this ``disclosure'' requirement 
would facilitate improved decision making by investors in the financial 
sector is difficult to take seriously.
    If climate ``risks'' are deemed material in terms of disclosure 
requirements, why not others that are uncertain or speculative? Climate 
``risks'' are hardly the only ones potentially relevant to the 
financial system but difficult to incorporate into business decisions. 
What about massive volcanic eruptions? Asteroid impacts? Powerful 
earthquakes? Tsunamis? The potential problem of mass contagion is one 
with which we are far more familiar now than was the case only a bit 
more than a year ago. The use of bioweaponry by terrorists, nuclear 
war, gamma ray storms, and on and on. Is climate ``risk'' the most 
important? If that is the hypothesis, what is the basis for it? Why are 
those others, and many more, not worthy of incorporation into financial 
decisions? What distortions would result from attention only to climate 
change and not others?
    Because the perceived ``climate ``risks'' confronting the financial 
sector are dependent upon crucial choices among alternative 
assumptions, the evaluation of such ``risks'' would be largely 
arbitrary given that the ``correct'' assumptions are very far from 
obvious. This means that a requirement, whether formal or informal, 
that climate ``risks'' be incorporated into the business decisions of 
financial institutions would weaken the materiality standard for 
disclosures by those institutions. ``Materiality'' always has meant the 
disclosure of information directly relevant to the financial 
performance of the bank or other institution. When ``risk'' analysis 
becomes an arbitrary function of choices among assumptions complex, 
opaque, and far from obvious, the traditional materiality standard 
inexorably will be diluted and rendered far less useful for the 
investment and financial markets, an outcome diametrically at odds with 
the ostensible objectives of those advocating the evaluation of climate 
``risks.''
Additional Observations and Conclusions
    The available analysis suggests that the financial risks of 
anthropogenic climate change, at least in the aggregate, are much 
smaller than many assert. Consider the predictions from the central 
integrated assessment models, one of which is the Dynamic Integrated 
Climate and Economy Model, for which William D. Nordhaus won the Nobel 
Prize in Economics in 2018. \35\ Under DICE, global gross domestic 
product (GDP) in 2100 varies by about 3 percent across policy 
scenarios, including no climate policies at all, a figure that is both 
very small and almost certainly not statistically significant given the 
vagaries of economic forecasting and the number of years remaining 
before the end of this century. (I exclude here Nordhaus' ``Stern 
discounting'' policy scenario, as it assumes a discount rate 
effectively equal to zero, a fundamental analytic error. \36\) Per 
capita consumption varies only by about 1.3 percent across policy 
scenarios, also a very small number and almost certain not to be 
statistically significant.
---------------------------------------------------------------------------
     \35\ See William Nordhaus and Paul Sztorc, ``DICE 2013R: 
Introduction and User's Manual,'' Yale University, Department of 
Economics, October 2013, Figure 4 and Table 1, http://
www.econ.yale.edu/nordhaus/homepage/homepage/documents/DICE-Manual-
100413r1.pdf. See also Benjamin Zycher, ``The Climate Left Attacks 
Nobel Laureate Willian D. Nordhaus,'' monograph, American Enterprise 
Institute, July 2020, at https://www.aei.org/wp-content/uploads/2020/
07/The-Climate-Left-Attacks-Nobel-Laureate-William-D.-Nordhaus.pdf.
     \36\ See, e.g., David Kreutzer, ``Discounting Climate Costs,'' 
Heritage Foundation, June 16, 2016, at https://www.heritage.org/
environment/report/discounting-climate-costs. See Nicholas Stern, The 
Economics of Climate Change: The Stern Review (Cambridge, UK: Cambridge 
University Press, January 2007), https://www.cambridge.org/us/academic/
subjects/earth-and-environmental-science/climatology-and-climate-
change/economics-climate-change-stern-review?format=PB.
---------------------------------------------------------------------------
    Proposals that the Federal Reserve enforce a mandate that financial 
institutions evaluate climate ``risks'' represent a blatant effort to 
distort the allocation of capital away from economic sectors disfavored 
by certain political interest groups pursuing ideological agendas. This 
would represent the return of Operation Choke Point, an attempt to 
politicize access to credit, one deeply corrosive of our legal and 
constitutional institutions. Protection of those institutions is 
consistent only with formal policymaking by the Congress through 
enactment of legislation, rather than with pressures, powerful but 
informal, exerted upon and by the Federal Reserve and other regulatory 
agencies. Because the uncertainties attendant upon the future effects 
of increasing atmospheric concentrations of GHG are so great, a top-
down policy approach for the evaluation of any attendant risks is 
itself very risky. A wiser approach would entail allowing market forces 
to make such ``risk'' determinations in a bottom-up fashion, thus 
avoiding an obvious politicization of the allocation of capital. It is 
reasonable to hypothesize that the market in its atomistic fashion has 
decided that it is the sum of decisions by financial institutions and 
investors that is the more reliable gauge of the highly uncertain 
business implications of evolving climate phenomena. So as to drive the 
appropriate responses from businesses, it is not necessary that all 
investors make such difficult judgments; it is necessary only that 
marginal investors do so. Financial institutions are not charities, and 
they are not government. The campaign for evaluation and disclosure of 
climate ``risks'' by the Federal Reserve and financial institutions is 
a clear effort to use private-sector resources for ideological 
purposes, in the context of the unwillingness of the Congress to enact 
such policies explicitly. The proper course in the context of climate 
phenomena is the preservation of the traditional roles of the private 
sector and of the government, respectively, as part of the larger 
permanent objectives of maximizing the productivity of resource use 
under free market competition, and preserving the political 
accountability of the policymaking process under the institutions of 
democratic decisionmaking as constrained by the constitution.
    Thank you, Chairman Brown and Ranking Member Toomey, for this 
opportunity to offer my views on this prominent topic. I will be very 
pleased to address any questions that you or the other Members of this 
Committee may have.
               RESPONSES TO WRITTEN QUESTIONS OF
           SENATOR CORTEZ MASTO FROM GREGORY GELZINIS

Q.1. How are financial firms considering the increase of 
migration due to extreme climate change? How would a financial 
institution that has long served its community plan for a 
possible fire, tornado or flood wiping out the town and 
uprooting and dispersing residents?

A.1. Unfortunately, regulators and the public have little 
information on how financial firms are considering the 
potential effects of climate change on their balance sheets and 
operations, including the effects of climate-driven migration. 
It is critical for regulators to compel the production of this 
information and also ensure, through supervision and other 
prudential means, that financial firms are adequately 
integrating these risk factors into their governance, risk 
management, internal controls, and capital planning processes.
    The damage caused by an extreme weather event can impair 
the value of physical assets and cause losses for the financial 
instruments tied to those assets. Migrations following extreme 
weather events or those driven by long-term environmental 
shifts can further reduce the value of real and financial 
assets in the region, e.g., a commercial loan to a small 
business that loses a large portion of its customer base or a 
mortgage in a housing market with depleted demand. Migration 
could also limit financial firms' ability to derive future 
business from the impacted region, reducing their 
profitability. These and other physical risks could threaten 
the safety and soundness of individual firms and further 
economically disrupt the communities they serve. Beyond this 
type of microprudential concern, physical risks could 
ultimately destabilize the broader financial system and inflict 
harm on the economy as a whole. Financial firms will not 
sufficiently address these risks on their own. Regulators must 
step in to improve the resilience of the financial system to 
these climate-related risks.

Q.2. We know that the insurance sector is particularly 
vulnerable to the physical impacts of climate change. We've 
seen fires, floods, tornadoes and other extreme weather events 
cause wide-scale devastation.
    Have insurance commissioners identified specific Federal 
actions to mitigate large-scale losses?
    How are State insurance commissioners ensuring that 
insurance firms consider and plan for risks?

A.2. The business model for property and casualty insurance 
companies, which guarantee the value of physical property 
against an array of perils, is acutely exposed to the physical 
risks of climate change. The increase in frequency and severity 
of floods, wildfires, hurricanes, and other extreme weather 
events threatens to drive unprecedented claims for insurers in 
impacted geographies and business lines. It is critical for 
state insurance commissioners to ensure the resiliency of these 
institutions. An increase in insurance company failures could 
threaten state guarantee funds, policyholders, counterparties, 
and the broader economy. Moreover, the less prepared an 
insurance company is for climate-related risks, the more likely 
it will rapidly pull back from certain geographies and business 
lines after a climate-related shock. That may help limit the 
future solvency risk of the insurance company, but it will 
increase the risks borne by businesses, households, and other 
financial firms that rely on insurance for risk mitigation.
    State insurance commissioners have generally refrained from 
identifying federal financial regulatory actions that could 
help mitigate climate-related risks to the financial system, 
given that insurers are predominantly regulated at the state 
level. A few state insurance regulators have taken initial 
steps, however, to identify and mitigate climate-related risks 
to insurers within their jurisdiction, but too few states have 
taken action on this front. California and New York have been 
two of the leading states. In 2016, CA Insurance Commissioner 
Dave Jones launched the Climate Risk Carbon Initiative to 
tackle climate-related insurance risks. \1\ The effort included 
enhanced climate risk disclosure and stress testing, among 
other measures. In 2019, the New York State Department of 
Financial Services (NYDFS) was the first U.S. financial 
regulator to join the Network for Greening the Financial 
System. Since then, NYDFS has issued a circular and proposed a 
guidance document that outlines climate-related supervisory 
expectations for insurers. \2\
---------------------------------------------------------------------------
     \1\ California Department of Insurance, ``Climate Risk Carbon 
Initiative,'' available at http://www.insurance.ca.gov/0250-insurers/
0300-insurers/0100-applications/ci/index.cfm.
     \2\ New York State Department of Financial Services, 
``Superintendent Lacewell Announces Proposed DFS Guidance To New York 
Insurers On Managing The Financial Risks From Climate Change,'' Press 
Release, March 25, 2021. Available at https://www.dfs.ny.gov/reports-
and-publications/press-releases/pr202103252.
---------------------------------------------------------------------------
    It is important for state insurance commissioners across 
the country that are lagging behind to pick up the pace of 
action. Climate risk disclosure, stress testing, supervisory 
guidance, and integrating climate considerations into the risk-
based capital framework would improve the resiliency of the 
insurance sector. Moreover, despite the potential lack of 
support for federal action among most state insurance 
commissioners, the Federal Insurance Office (FIO) and Financial 
Stability Oversight Council (FSOC) have a vital role to play on 
this issue. The FIO and FSOC should push states to act and use 
their own federal tools to mitigate these risks, where 
appropriate.

Q.3. At the Securities and Exchange Commission, Acting 
Commissioner Lee has suggested improvements to disclosure 
related to investments
    Do investors know the actual climate risks to their 
portfolios?

A.3. A survey of institutional investors suggests the financial 
system is not reflecting these risks in asset prices, as 93 
percent responded that the implications of climate change had 
yet to be priced into markets. \3\ Research surrounding the 
projected physical impacts of climate change and scenario 
analyses probing transition-related impacts support this view. 
\4\ There are several reasons that investors have yet to price 
the impacts of climate change into valuations for a range of 
assets. These include a lack of granular, comparable, and 
reliable corporate disclosure of climate-related risks; 
backwards-looking pricing models that are not fit for purpose 
when analyzing forward-looking risks; and the temporal mismatch 
between short-term corporate thinking and medium-to-long term 
climate risk materialization. \5\
---------------------------------------------------------------------------
     \3\ asset-allocation-finds-new-report-by-bny-mellon-investm.
     \4\ Felix Suntheim and Jerome Vandenbussche, ``Equity Investors 
Must Pay More Attention to Climate Change Physical Risk,'' 
International Monetary Fund, May 29, 2020, available at https://
blogs.imf.org/2020/05/29/equity-investors-must-pay-more-attention-to-
climate-change-physical-risk/; See for example, De Nederlandsche Bank, 
``An energy transition risk stress test for the financial system of the 
Netherlands,'' (2018), available at https://www.dnb.nl/media/pdnpdalc/
201810-nr-7-2018-an-energy-transition-risk-stress-test-for-the-
financial-system-of-the-netherlands.pdf and Irene Monasterolo, 
``Assessing climate risks in investors' portfolios: a journey through 
climate stress-testing,'' U.N. Principles for Responsible Investment, 
March 2, 2020, available at https://www.unpri.org/pri-blog/assessing-
climate-risks-in-investors-portfolios-a-journey-through-climate-stress-
testing/5526.article.
     \5\ Madison Condon, ``Market Myopia's Climate Bubble,'' Boston 
University School of Law, Law and Economics Research Paper Forthcoming 
(2021), available at https://papers.ssrn.com/sol3/papers.cfm?abstract-
id=3782675.

Q.4. Is it possible for investors to know the actual climate 
---------------------------------------------------------------------------
risk in their portfolios?

A.4. Investors need reliable, consistent, and comparable data 
to evaluate the climate-related risk in their portfolios. The 
myriad voluntary disclosure frameworks that have developed over 
the past several years have helped get the ball rolling on this 
important issue, but only a mandatory standardized regime 
implemented by the SEC can provide the information necessary 
for investors to make prudent decisions when they allocate 
capital. The disclosures should include both specific line-item 
quantitative requirements and additions to the narrative-based 
disclosures in the management discussion and analysis, such as 
those called for by the Task Force on Climate-related Financial 
Disclosures. \6\
---------------------------------------------------------------------------
     \6\ Task Force on Climate-related Financial Disclosures, 
``Implementing the Recommendations of the Task Force on Climate-related 
Financial Disclosures,'' (2017), available at https://assets.bbhub.io/
company/sites/60/2020/10/FINAL-TCFD-Annex-Amended-121517.pdf; Alexandra 
Thornton and Andy Green, ``The SEC's Time To Act'' (Washington: Center 
for American Progress, 2021), available at https://
www.americanprogress.org/issues/economy/reports/2021/02/19/496015/secs-
time-act/.
---------------------------------------------------------------------------
                                ------                                


               RESPONSES TO WRITTEN QUESTIONS OF
          SENATOR CORTEZ MASTO FROM NATHANIEL KEOHANE

Q.1. How does extreme weather events due to climate change pose 
risks to the hospitality and tourism sector? How should 
communities that rely on tourism and hospitality jobs plan for 
climate change impacts?

A.1. Extreme weather events caused by climate change can have 
severe consequences for local recreation and tourism 
industries, ranging from skiing to national park visitation to 
urban excursions. The scope and magnitude of these impacts on 
residents and out-of-state visitors--and the businesses that 
support them--are likely to grow in the future. They will also 
put increasing pressure on the budgets of the federal, state, 
and local agencies charged with managing park and recreation 
lands and facilities. \1\
---------------------------------------------------------------------------
     \1\ Van Houtven et al., 2020. Climate Change and North Carolina: 
Near-term Impacts on Society and Recommended Actions. RTI 
International. Available at: https://www.edf.org/sites/default/files/
content/NC-Costs-of-Inaction.pdf.
---------------------------------------------------------------------------
    Nevada in particular is already experiencing the effects of 
a changing climate. The state's average temperature is 
increasing, with 8 of the 10 warmest years since 1895 having 
occurred since 2000. Annual average temperature increases of 4-
6 degrees Fahrenheit are projected across the state by 2050. 
Under a high-emissions scenario, most of central and northern 
Nevada could see increases of 10-12 degrees by the end of the 
century. \2\
---------------------------------------------------------------------------
     \2\ Nevada Climate Initiative, 2020. State Climate Strategy. 
Available at: https://climateaction.nv.gov/wp-content/uploads/2021/01/
NVClimateStrategy-011921.pdf.
---------------------------------------------------------------------------
    Reno and Las Vegas are already experiencing particularly 
severe warming, due to the urban heat island effect--in which a 
city's built infrastructure prevents heat from dissipating as 
temperatures cool overnight.
    Nevada is also likely to experience increased droughts, 
snow loss, and flooding due to climate change. By 2050, 5-10 
percent more of total precipitation could fall as rain rather 
than snow--with even higher numbers in the Tahoe basin and 
northwestern part of the state. Peak runoff rates are projected 
to rise more than 25-50 percent above the state's historical 
rates by 2050, particularly around many mountain ranges and the 
Las Vegas Valley. \3\
---------------------------------------------------------------------------
     \3\ Ibid. Both projections are 2050 estimates, under an RCP8.5 
(i.e., high-emission) climate scenario.
---------------------------------------------------------------------------
    These climate impacts stand to have significant 
implications for Nevada's tourism, recreation, and hospitality 
sectors. For example:

    Shorter snow seasons and less reliable snowpack 
        could affect Nevada's ski season and reduce associated 
        tourism in an industry that generates hundreds of 
        millions in annual revenue. \4\
---------------------------------------------------------------------------
     \4\ For example, a study from Patrick Tierney at SF State found 
the ski industry contributed $564 million to the local Tahoe area 
economy during the 2013-14 winter season. Meanwhile, a report from 
Tourism Economics found that outdoor recreation accounted for $966 
million of visitor spending in Nevada in 2018.

    Higher temperatures in the summer, coupled with 
        increased dust caused by drought, can deter visitors 
        and reduce the time available to be safely outside. By 
        2050, Great Basin National Park, for example, is 
        projected to experience 58 days per year of 
        temperatures over 90 degrees--up from the current 
        average of 19. \5\
---------------------------------------------------------------------------
     \5\ Kahn, 2016. ``The Future of National Parks is Going to be a 
Lot Hotter.'' Climate Central. Available at: http://
assets.climatecentral.org/pdfs/NationalParks-daysabove.pdf.

    Increased temperatures and heat waves are expected 
        to lead to greater energy demand for air conditioning 
        and cooling, placing additional cost pressures on local 
        businesses. In Clark County, where Las Vegas is 
        located, increased annual energy expenditures could 
        reach between 15-20 percent by end-of-century under a 
        pessimistic climate scenario (RCP8.5). \6\
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     \6\ Hsiang, S., Kopp, R., Jina, A., Rising, J., Delgado, M., 
Mohan, S., Rasmussen, D.J., Muir-Wood, R., Wilson, P., Oppenheimer, M. 
and Larsen, K., 2017. Estimating economic damage from climate change in 
the United States. Science, 356(6345), pp.1362-1369. Available at: 
https://science.sciencemag.org/content/sci/356/6345/1362.full.pdf.

    The labor supply of Nevada workers heavily exposed 
        to outdoor temperatures is expected to decline between 
        1-2 percent by end-of-century under a pessimistic 
        climate scenario (RCP8.5). Many of these jobs support 
        tourism and recreation across the state. \7\
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     \7\ Ibid.

    More severe droughts have the potential to 
        adversely affect a wide variety of water-based 
        recreational activities as well as the golfing 
        industry, which supports more than a billion of annual 
        revenue and 4,000 jobs. \8\
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     \8\ Repetto, 2012. Economic and Environmental Impacts of Climate 
Change in Nevada. Demos. Available at https://www.demos.org/research/
economic-and-environmental-impacts-climate-change-nevada#Climate-
Change's-Impact-on-Tourism-in-Nevada.

    Increased severity and frequency of droughts will 
        likely result in more wildfires across the state. This 
        would affect the state's extensive parks and recreation 
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        lands by reducing visitation and associated revenue.

    Increased flash flooding could cause disruptions in 
        downtown areas of Reno and Las Vegas, while road 
        closures due to flood and landslide risk can disrupt 
        travel plans throughout the state. \9\
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     \9\ Nevada Climate Initiative, 2020. State Climate Strategy. 
Available at: https://climateaction.nv.gov/wp-content/uploads/2021/01/
NVClimateStrategy-011921.pdf.

    Many ski areas and mountain communities have responded to a 
changing climate by expanding their traditional tourist 
offerings--for example, by expanding their summer and 
traditional ``mud season'' offerings to include hiking, 
mountain biking, and adventure parks as a way to generate 
revenue during the off season. However, these solutions only 
offer short-term revenue patches, and they must be complemented 
by longer-term policy and investment decisions.
    The most important way to protect such communities from the 
impacts of climate change is to enact policies that reduce 
emissions of carbon dioxide, methane, and other heat-trapping 
greenhouse gases that are responsible for climate change. While 
there is no substitute for Federal action on climate, state 
initiatives are essential to making critical near-term 
reductions, helping mitigation of greenhouse gas emissions and 
offering a roadmap for ambitious Federal action. For example, 
Nevada Governor Steve Sisolak recently announced new rulemaking 
to promote low- and zero-emissions vehicles, complementing the 
state's latest renewable portfolio standard requiring 50 
percent carbon-free electricity by 2030.\10\ \11\ Most 
recently, the Nevada Climate Initiative issued its inaugural 
State Climate Strategy in December, outlining several policy 
options to meet the state's 2050 decarbonization goals--
including an enforceable cap on emissions. \12\
---------------------------------------------------------------------------
     \10\ EDF, 2020. ``Nevada Governor Sisolak Takes Important First 
Step Toward Transportation Electrification.'' Available at https://
www.edf.org/media/nevada-governor-sisolak-takes-important-first-step-
toward-transportation-electrification.
     \11\ Morehouse, 2019. ``Nevada Passes Bill for 50 percent 
Renewables by 2030, 100 percent Carbon Free by 2050.'' Utility Dive. 
Available at https://www.utilitydive.com/news/nevada-passes-bill-for-
50-renewables-by-2030-100-carbon-free-by-2050/553138/.
     \12\ EDF, 2020. ``Nevada's State Climate Strategy Signals Need for 
More Ambitious Policies to Curb Pollution.'' Available at https://
www.edf.org/media/nevadas-state-climate-strategy-signals-need-more-
ambitious-policies-curb-pollution.
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    In addition, communities can plan for climate change 
impacts by making investments in stormwater management systems 
and other climate-resilient infrastructure; integrating 
projections of future climate impacts into land use planning 
and zoning (e.g., increasing green space can help reduce the 
``heat island'' effect mentioned above that exacerbates 
warming); and, especially in semi-arid regions like Nevada, 
integrating projections of climate impacts into long-range 
planning for water infrastructure and use. \13\
---------------------------------------------------------------------------
     \13\ Several such policy options are outlined in Nevada Climate 
Initiative, 2020. State Climate Strategy. Available at: https://
climateaction.nv.gov/wp-content/uploads/2021/01/NVClimateStrategy-
011921.pdf.

Q.2. At the Securities and Exchange Commission, Acting 
Commissioner Lee has suggested improvements to disclosure 
related to investments.
    Do investors know the actual climate risks to their 
portfolios?

A.2. Investors in general do not currently know the actual 
climate risks to their portfolios--because the information 
needed for them to do so is not widely available with the 
consistency, quality, and specificity required. This conclusion 
emerges clearly from the report by the Climate-Related Market 
Risk Subcommittee of the Commodity Futures Trading Commission, 
of which I was a member. \14\
---------------------------------------------------------------------------
     \14\ Commodity Futures Trading Commission (CFTC), Managing Climate 
Risk in the U.S. Financial System, Report of the Climate-Related Market 
Risk Subcommittee of the Market Risk Advisory Committee (2020), p. v, 
https://perma.cc/UT9M-FG2Y (``The existing disclosure regime has not 
resulted in disclosures of a scope, breadth, and quality to be 
sufficiently useful to market participants and regulators.'').
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    Climate change poses significant physical and transition 
risks for companies across economic sectors and geographic 
locations. \15\ In light of that fact, the SEC promulgated its 
2010 guidance confirming that climate-related risks should be 
disclosed in the same manner as other financial risks to 
companies, \16\ and well over 1,000 companies have signed onto 
the TCFD voluntary framework for additional climate disclosure. 
\17\
---------------------------------------------------------------------------
     \15\ CFTC, Managing Climate Risk in the U.S. Financial System, 11.
     \16\ Commission Guidance Regarding Disclosure Related to Climate 
Change, Securities Act Release No. 9106, Exchange Act Release No. 
61,469, 75 Fed. Reg. 6290 (Feb. 8, 2010).
     \17\ Parker Bolstad et al., ``Flying Blind: What Do Investors 
Really Know About Climate Change Risks in the U.S. Equity and Municipal 
Debt Markets?'' (Brookings Institute, 2020), p. 2, https://perma.cc/
8LNV-BEGK.
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    However, a large proportion of companies are not making 
disclosures that would allow investors to meaningfully assess 
climate risk. A 2017 KPMG study of the annual financial reports 
of nearly 5,000 companies found that only 28 percent 
acknowledged financial risk of climate change at all. \18\ 
Among the 250 largest companies, the rate of acknowledgment was 
higher but still under 50 percent. \19\
---------------------------------------------------------------------------
     \18\ KPMG, ``The Road Ahead: The KPMG Survey of Corporate 
Responsibility Reporting 2017'', p. 30, https://assets.kpmg/content/
dam/kpmg/be/pdf/2017/kpmg-survey-of-corporate-responsibility-reporting-
2017.pdf.
     \19\ KPMG, ``The Road Ahead'', p. 31.
---------------------------------------------------------------------------
    Furthermore, many reports that do reference climate risk 
have considerable limitations. Only 2 percent of the companies 
in the KPMG study that acknowledged climate risks quantified 
those potential risks in financial terms; a similarly low 
percentage modeled potential impacts using scenario analysis. 
\20\ The TCFD's 2020 status report found that only 17 percent 
of companies discuss their process for integrating climate 
change into risk management, while only 7 percent of companies 
discuss their resilience strategies. \21\
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     \20\ KPMG, ``The Road Ahead'', p. 31.
     \21\ TCFD, 2020 Status Report, p. 11-12, https://www.fsb.org/wp-
content/uploads/P291020-1.pdf.
---------------------------------------------------------------------------
    In order for disclosures to be sufficient, they must be 
specific to the company, comparable to other companies, and 
useful in making decisions on investment, ownership, 
engagement, and proxy-voting. \22\ Without broad access to 
specific, comparable, and decision-useful disclosures, 
investors are not able to reliably assess climate risks to 
their portfolios. At a system level, this lack of information 
has created the danger of a ``climate bubble'' through 
mispricing of risky assets. \23\
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     \22\ Madison Condon et al., ``Mandating Disclosure of Climate-
Related Financial Risk'', NYU Institute for Policy Integrity and 
Environmental Defense Fund, 2021, p. 11, https://perma.cc/2USW-MMXF.
     \23\ Madison Condon, ``Market Myopia's Climate Bubble 2021'' Utah 
L. Rev. (forthcoming 2021), https://papers.ssrn.com/sol3/
papers.cfm?abstract-id=3782675.

Q.3. Is it possible for investors to know the actual climate 
---------------------------------------------------------------------------
risk in their portfolios?

A.3. It is certainly possible to greatly improve the quantity 
and quality of climate risk information available to investors 
by ``deploying new analytical tools, regulatory incentives, and 
business practices.'' \24\
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     \24\ Parker Bolstad et al., ``Flying Blind'', 4.
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    Tools for climate risk analysis are advancing rapidly. The 
Paris Agreement Capital Transition Assessment (PACTA), for 
example, aggregates corporate climate risk information to allow 
financial institutions to assess both asset-specific and 
portfolio-wide alignment with various climate scenarios. To 
date, over 3,000 financial institutions globally have used the 
PACTA tool. \25\ The Climate Action 100+ Net Zero Benchmark and 
Transition Pathway Initiative, along with ESG ratings products 
from firms like MSCI and Sustainalytics, also provide investors 
with increasingly robust resources to model climate risk.
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     \25\ 2 Degree Investing Initiative, ``PACTA/Climate Scenario 
Analysis Program,'' https://2degrees-investing.org/resource/pacta/.
---------------------------------------------------------------------------
    These tools can improve with enhanced corporate climate 
risk disclosure. Over the past three years, a growing consensus 
of investors have called for TCFD-aligned disclosure to better 
evaluate portfolio-wide climate-related financial risks. \26\ 
That the number of companies reporting in line with the TCFD 
continues to increase annually suggests that enhancing climate 
risk analysis is achievable. \27\ Additionally, the 
proliferation of downscaled climate projections can help make 
investor analysis of company-specific physical risks more 
sophisticated. \28\
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     \26\ The Yale Center for Business and the Environment, Investors 
Push the Pace of Climate Risk Financial Disclosures (2018), p. 2, 
https://www.erm.com/globalassets/documents/publications/2018/yalecbe-
erm-investors-push-the-pace-on-climate-risk-financial-disclosures.pdf.
     \27\ TCFD, 2019 Status Report, p. 5, (``Overall, the Task Force 
found signs of progress in implementing the recommendations among 
companies traditionally engaged on climate-related issues. These 
companies demonstrate that disclosing climate-related information 
consistent with the TCFD recommendations is possible and is a journey 
of continuing improvement.'').
     \28\ See, e.g., U.S. Climate Resilience Toolkit, Energy Data 
Gallery, https://toolkit.climate.gov/topics/energy/energy-data-gallery 
(last updated Sept. 24, 2019); Nat'l Aeronautics & Space Admin., NASA 
Earth Exchange (NEX) Downscaled Climate Projections (NEX-DCP30), 
https://www.nccs.nasa.gov/services/data-collections/land-based-
products/nex-dcp30 (last visited Apr. 14, 2021); U.S. Geological 
Survey, Regional Climate Change Viewer, http://
regclim.coas.oregonstate.edu/visualization/rccv/index.html (last 
visited Apr. 14, 2021); Bureau of Reclamation et al., Downscaled CMIP3 
and CMIP5 Climate and Hydrology Projections, https://gdo-
dcp.ucllnl.org/downscaled-cmip-projections/#Welcome (last visited Apr. 
14, 2021); Conservation Biology Inst., Adapt West-A Climate Adaptation 
Conservation Planning Database for North America, https://
adaptwest.databasin.org/ (last visited Apr. 14, 2021).
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    Regulators can facilitate wider adoption of best practices 
through many avenues, including mandating climate risk 
disclosures, building climate expertise, requiring financial 
firms to consider climate risk, and facilitating availability 
and consistency of climate data. \29\ Leading investors 
including BlackRock, the world's largest asset manager, have 
called for mandatory climate risk disclosure, noting that 
``consistent, high-quality and material public information.will 
enable both asset owners and asset managers to make more 
informed decisions about how to achieve long-term returns.'' 
\30\ Through regulatory action, corporate initiative, and 
technological innovation, investors can determine portfolio-
wide climate risks with increasing accuracy.
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     \29\ CFTC, Managing Climate Risk in the U.S. Financial System; see 
particularly the Key Recommendations summarized on pages vi-ix.
     \30\ Larry Fink, ``To Our Shareholders,'' (Jan, 26, 2021), https:/
/www.blackrock.com/corporate/investor-relations/larry-fink-chairmans-
letter.
              Additional Material Supplied for the Record
           MANAGING CLIMATE RISK IN THE U.S. FINANCIAL SYSTEM
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