[Federal Register Volume 87, Number 64 (Monday, April 4, 2022)]
[Notices]
[Pages 19507-19512]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2022-07065]
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FEDERAL DEPOSIT INSURANCE CORPORATION
RIN 3064-ZA32
Statement of Principles for Climate-Related Financial Risk
Management for Large Financial Institutions
AGENCY: Federal Deposit Insurance Corporation.
ACTION: Notice of proposed policy statement; request for comment.
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SUMMARY: The Federal Deposit Insurance Corporation (FDIC) is requesting
comment on draft principles that would provide a high-level framework
for the safe and sound management of exposures to climate-related
financial risks. Although all financial institutions, regardless of
size, may have material exposures to climate-related financial risks,
these draft principles are targeted at the largest financial
institutions, those with over $100 billion in total consolidated
assets. The draft principles are intended to support efforts by large
financial institutions to focus on key aspects of climate-related
financial risk management.
DATES: Comments must be received no later than June 3, 2022.
ADDRESSES: Commenters are encouraged to use the title ``Principles for
Climate-
[[Page 19508]]
Related Financial Risk Management for Large Financial Institutions''
(RIN 3064-ZA32) and to identify the number of the specific question(s)
for comment to which they are responding. Please send comments by one
method only directed to:
Agency Website: https://www.fdic.gov/resources/regulations/federal-register-publications/index.html. Follow the
instructions for submitting comments on the agency's website.
Email: [email protected]. Include RIN 3064-ZA32 in the
subject line of the message.
Mail: James P. Sheesley, Assistant Executive Secretary,
Attention: Comments--RIN 3064-ZA32, Federal Deposit Insurance
Corporation, 550 17th Street NW, Washington, DC 20429.
Hand Delivery/Courier: Comments may be hand-delivered to
the guard station at the rear of the 550 17th Street NW building
(located on F Street NW) on business days between 7:00 a.m. and 5:00
p.m.
Public Inspection: All comments received will be posted
without change to https://www.fdic.gov/resources/regulations/federal-register-publications/index.html--including any personal information
provided--for public inspection. Paper copies of public comments may be
ordered from the FDIC Public Information Center, 3501 North Fairfax
Drive, Room E-1002, Arlington, VA 22226 or by telephone at 877-275-3342
or 703-562-2200.
FOR FURTHER INFORMATION CONTACT: Andrew D. Carayiannis, Senior Policy
Analyst, Capital Markets Strategies Section, [email protected];
Lauren K. Brown, Senior Policy Analyst, Exam Support Section,
[email protected]; [email protected]; Capital Markets and
Accounting Policy, Division of Risk Management Supervision, 202-898-
6888; Jennifer M. Jones, Counsel, [email protected]; Karlyn Hunter,
Counsel, [email protected]; Amanda Ledig, Senior Attorney,
[email protected]; Supervision and Legislation, and Enforcement Branch,
Legal Division, Federal Deposit Insurance Corporation, 550 17th Street
NW, Washington, DC 20429. For the hearing impaired only,
Telecommunication Device for the Deaf (TDD), 800-925-4618.
SUPPLEMENTARY INFORMATION:
Table of Contents
I. Introduction
II. General Principles
A. Governance
B. Policies, Procedures, and Limits
C. Strategic Planning
D. Risk Management
E. Data, Risk Measurement, and Reporting
F. Scenario Analysis
III. Management of Risk Areas
A. Credit Risk
B. Liquidity Risk
C. Other Financial Risk
D. Operational Risk
E. Legal/Compliance Risk
F. Other Nonfinancial Risk
IV. Paperwork Reduction Act
V. Request for Comment
I. Introduction
The effects of climate change and the transition to a low carbon
economy present emerging economic and financial risks that threaten the
safety and soundness of financial institutions and the stability of the
financial system.1 2 Financial institutions are likely to be
affected by both the physical risks and transition risks associated
with climate change (referred to in these draft principles as climate-
related financial risks). Physical risks generally refer to the harm to
people and property arising from acute, climate-related events, such as
hurricanes, wildfires, floods, and heatwaves, and chronic shifts in
climate, including higher average temperatures, changes in
precipitation patterns, sea level rise, and ocean acidification.
Transition risks generally refer to stresses to certain financial
institutions or sectors arising from the shifts in policy, consumer and
business sentiment, or technologies associated with the changes
necessary to limit climate change.
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\1\ In this issuance, the term ``financial institution'' or
``institution'' means insured state nonmember banks, state-licensed
insured branches of foreign banks that are subject to the provisions
of section 39 of the Federal Deposit Insurance Act, and state
savings associations.
\2\ For additional background, see generally Financial Stability
Oversight Council, Report on Climate-Related Financial Risk (2021).
Further, see Financial Stability Board, The Implications of Climate
Change for Financial Stability (2020).
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The economic and financial risks associated with physical risks
reflect damages to property, infrastructure, and business disruptions,
all of which have real effects to the value of property securing
financial institutions' exposures and borrowers' ability to perform on
their obligations.\3\ Regarding transition risks, certain companies or
sectors may become less competitive over time as policies implemented
to reduce carbon emissions or carbon-equivalents to mitigate the risks
of climate change (e.g., carbon pricing), technological advances, and
changes in investor and public preferences may all contribute to and
accelerate a transition to a low-carbon economy, in each case
potentially resulting in reduced profitably and ability to repay
obligations for financial institutions' counterparties, as well as
reductions in the value for certain assets that are less productive in
a low-carbon environment.4 5 Transition risks may also
increase litigation, liability, legal and regulatory compliance risks
associated with climate-sensitive investments and businesses, or pose
other risks to institutions based on shifts in market or consumer
preferences. Additionally, the value of financial assets may be
adversely affected as market participants reflect the future impacts of
both physical and transition risks on financial performance.
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\3\ For example, acute physical risks, such as flooding,
hurricanes, wildfires, and droughts, may result in sudden,
significant, and recurring damage to residential and commercial real
estate properties securing exposures held by financial institutions
or may otherwise disrupt the operations of their business clients.
Further, longer-term gradual physical risks, such as rising average
temperatures and sea levels may increase the risk to property values
and drive migration patterns as individuals and businesses
prioritize geographic areas less exposed to physical risks, which
may produce detrimental impacts to household wealth, corporate
profitably, local economies and municipalities in certain
geographies. See www.whitehouse.gov, Report on the impact of climate
change on migration (2021) https://www.whitehouse.gov/wp-content/uploads/2021/10/Report-on-the-Impact-of-Climate-Change-on-Migration.pdf.
\4\ Reductions in carbon emissions are often considered through
a ``carbon equivalent amount'', which measures the emissions of
various greenhouse gases in terms of their equivalent amount of
carbon dioxide with the same global warming potential. For example,
see Equation A-1 in 40 CFR part 98.
\5\ For example, it may become more costly or difficult for
certain climate-sensitive investments and businesses to comply with
climate policies. Further, delayed implementation of climate
policies may result in a more abrupt transition for such climate-
sensitive investments and businesses, increasing the risks and
ultimate costs of transitioning to a more sustainable economy.
Advancements in technology may also accelerate the development of
low-carbon energy sources, while investor and public preferences and
behavior may result in a shift towards more energy efficient assets
and companies earlier than otherwise expected. See Network of
Central Banks and Supervisors for Greening the Financial System,
NGFS Climate Scenarios for Central Banks and Supervisors (2020); IEA
and IRENA, Perspectives for the energy transition--Investment needs
for a low-carbon energy system (2017).
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From a financial stability perspective, climate-related financial
risks have the potential to impact financial institutions and the
economy through both macroeconomic and microeconomic factors, such as
reductions in economic growth and labor productivity, increased
borrowing costs, and higher commodities prices, as well as directly to
financial institutions themselves or through their counterparties.\6\
These
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factors contribute to the way in which climate-related financial risks
can transmit to a significant number of financial institutions and
raise financial stability concerns.
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\6\ For example, physical and transition risks also have the
potential to produce ``feedback loops'' across the financial system
and economy, which can amplify and reinforce the impacts of climate
change through procyclical behavior, such as widespread reduction in
bank lending and lead to declines in asset valuations and economic
growth. Further, interconnections within the financial system can
accelerate the spread of a climate-related financial shocks, leading
to potential contagion effects if institutions experience shocks as
a result of physical or transition risks. See, for example,
Financial Stability Board, The Implications of Climate Change for
Financial Stability (2020); Basel Committee on Banking Supervision,
Climate-related risk drivers and their transmission channels (2021).
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Climate-related financial risks pose a clear and significant risk
to the U.S. financial system and, if unmitigated, may pose a near-term
threat to safe and sound banking and financial stability. Weaknesses in
how institutions identify, measure, monitor, and control the physical
and transition risks associated with a changing climate could adversely
affect a financial institution's safety and soundness, as well as the
overall financial system. Adverse effects could include potentially
disproportionate impact on the financially vulnerable, including low-
to moderate-income (LMI) and other disadvantaged households and
communities.\7\ With this, the manner in which financial institutions
manage climate-related financial risks to address safety and soundness
concerns should also seek to reduce or mitigate the impact that
management of these risks may have on broader aspects of the economy,
including the disproportionate impact of risk on LMI and other
disadvantaged communities.
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\7\ For further information, see Staff Reports, Federal Reserve
Bank of New York, Understanding the Linkages between Climate Change
and Inequality in the United States, No. 991 (November 2021).
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The FDIC recognizes the need for comprehensive risk management
guidelines that can be implemented consistently. These draft principles
provide a high-level framework for the safe and sound management of
exposures to climate-related financial risks, consistent with the risk
management framework described in existing FDIC rules and guidance, and
are intended to support efforts by financial institutions to focus on
the key aspects of climate risk management.\8\ The draft principles
will help financial institution management make progress toward
answering key questions on climate exposures and incorporating climate-
related financial risks into financial institutions' risk management
frameworks. Additionally, the draft principles are intended to support
the use of scenario analysis as an emerging and important approach for
identifying, measuring, and managing climate-related risks, as well as
risk assessment processes related to credit, liquidity, operational,
legal and compliance, and other financial and nonfinancial risks. Some
financial institutions, including many large financial institutions,
are considering climate-related risks and would benefit from additional
guidance as they develop capabilities, deploy resources, and make
necessary investments to address climate-related financial risks.
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\8\ The FDIC has established standards for safety and soundness,
as required by section 39 of the Federal Deposit Insurance Act, in
part 364 of FDIC Rules and Regulations.
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Although all financial institutions, regardless of size, may have
material exposures to climate-related financial risks, these draft
principles are targeted at the largest financial institutions, those
with over $100 billion in total consolidated assets.\9\ The draft
principles are an initial step to promote a consistent understanding of
the effective management of climate-related financial risks. The FDIC
plans to elaborate on these draft principles in subsequent guidance
that would distinguish roles and responsibilities of boards of
directors (boards) and management, incorporate the feedback received on
the draft principles, and consider lessons learned and best practices
from the industry and other jurisdictions. In keeping with the FDIC's
risk-based approach to supervision, the FDIC intends to appropriately
tailor any resulting supervisory expectations to reflect differences in
institutions' circumstances such as complexity of operations and
business models. Through this and any subsequent climate-related
financial risk guidance, the FDIC will continue to encourage
institutions to prudently meet the financial services needs of their
communities.
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\9\ Generally, effective risk management practices should be
appropriate to the size of the institution and the nature, scope,
and risk of its activities. See, e.g., Appendix A to part 364. For
purposes of these draft principles, the FDIC generally believes that
these standards are particularly salient for the largest financial
institutions, those with over $100 billion in total consolidated
assets.
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II. General Principles
A. Goverance
An effective risk governance framework is essential to a financial
institution's safe and sound operation. A financial institution's board
and management should demonstrate an appropriate understanding of
climate-related financial risk exposures and their impact on risk
appetite to facilitate oversight. Sound governance includes reviewing
information necessary to oversee the financial institution, allocating
appropriate resources, assigning climate-related financial risk
responsibilities throughout the organization (i.e., committees,
reporting lines, and roles), and clearly communicating to staff
regarding climate-related impacts to the institution's risk profile.
Responsibility and accountability may be integrated within existing
organizational structures or by establishing new structures for
climate-related financial risks. Where dedicated units are established,
the board and management should clearly define these units'
responsibilities and interaction with existing governance structures.
The board should have adequate understanding and knowledge to
assess the potential impact of climate-related risks on the financial
institution and to address and oversee these risks within the
institution's strategy and risk appetite, including an understanding of
the potential ways in which these risks could evolve over various time
horizons and scenarios. Relevant time horizons may include those that
extend beyond the institution's typical strategic planning horizon. The
board should actively oversee the financial institution's risk-taking
activities and hold management accountable for adhering to the risk
governance framework. Management is responsible for executing the
financial institution's overall strategic plan. This responsibility
includes effectively managing all risks, including climate-related
financial risks, and their effects on the institution's financial
condition. Management should also hold staff accountable for
controlling risks within established lines of authority and
responsibility. Additionally, management is responsible for regularly
reporting to the board on the level and nature of risks to the
institution, including climate-related financial risks.
B. Policies, Procedures, and Limits
Management should incorporate climate-related risks into policies,
procedures, and limits to provide detailed guidance on the
institution's approach to these risks in line with the strategy and
risk appetite set by the board. Policies, procedures, and limits should
be modified when necessary to reflect the distinctive characteristics
of climate-related risks and changes to the institution's activities.
C. Strategic Planning
The board and management should consider material climate-related
financial risk exposures when setting the institution's overall
business
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strategy, risk appetite, and financial, capital, and operational plans.
As part of forward-looking strategic planning, the board and management
should address the potential impact of climate-related financial risk
exposures on the institution's financial condition, operations
(including geographic locations), and business objectives over various
time horizons. The board and management should also consider climate-
related financial risk impacts on stakeholders' expectations, the
institution's reputation, and LMI and other disadvantaged households
and communities, including physical harm or access to bank products and
services. The FDIC recognizes that the incorporation of material
climate-related financial risks into various planning processes is
iterative as measurement methodologies, models, and data for analyzing
these risks continue to evolve and mature over time.
Any climate related strategies, including any relevant corporate
social responsibility objectives, should align with and support the
institution's broader strategy, risk appetite and risk management
framework. In addition, where institutions engage in public
communication of their climate-related strategies, boards and
management should ensure that any public statements about an
institution's climate related strategies and commitments are consistent
with their internal strategies and risk appetite statements.
D. Risk Management
Climate-related financial risks typically impact financial
institutions through a range of traditional risk types. Management
should oversee the development and implementation of processes to
identify, measure, monitor, and control climate-related financial risk
exposures within the institution's existing risk management framework.
A financial institution should employ a comprehensive process to
identify emerging and material risks stemming from the institution's
business activities and associated exposures. The risk identification
process should include input from stakeholders across the organization
with relevant expertise (e.g., business units, independent risk
management, and legal). Risk identification includes assessment of
climate-related financial risks across a range of plausible scenarios
and under various time horizons.
As part of sound risk management, institutions should develop
processes to measure and monitor material climate-related financial
risks and to inform management about the materiality of those risks.
Material climate-related financial risk exposures should be clearly
defined, aligned with the institution's risk appetite, and supported by
appropriate metrics (e.g., risk limits and key risk indicators) and
escalation processes. Boards and management should also incorporate
climate-related risks into their internal control frameworks, including
internal audit.
Tools and approaches for measuring and monitoring exposure to
climate-related risks include, among others, exposure analysis, heat
maps, climate risk dashboards and scenario analysis. These tools can be
leveraged to assess an institution's exposure to both physical and
transition risks in both the shorter and longer term. Outputs should
inform the risk identification process and the short- and long-term
financial risks to an institution's business model from climate change.
E. Data, Risk Measurement, and Reporting
Sound climate risk management depends on the availability of
relevant, accurate, and timely data. Management should incorporate
climate-related financial risk information into the institution's
internal reporting, monitoring, and escalation processes to facilitate
timely and sound decision-making across the institution. Effective risk
data aggregation and reporting capabilities allow management to capture
and report material and emerging climate-related financial risk
exposures, segmented or stratified by physical and transition risks,
based upon the complexity and types of exposures. Data, risk
measurement, modeling methodologies, and reporting continue to evolve
at a rapid pace; management should monitor these developments and
incorporate them into their climate risk management as warranted.
F. Scenario Analysis
Climate-related scenario analysis is emerging as an important
approach for identifying, measuring, and managing climate-related
risks. For the purposes of this guidance, climate-related scenario
analysis refers to exercises used to conduct a forward-looking
assessment of the potential impact on an institution of changes in the
economy, financial system, or the distribution of physical hazards
resulting from climate-related risks. These exercises differ from
traditional stress testing exercises that typically assess the
potential impacts of transitory shocks to near-term economic and
financial conditions. An effective climate-related scenario analysis
framework provides a comprehensive and forward-looking perspective that
institutions can apply alongside existing risk management practices to
evaluate the resiliency of an institution's strategy and risk
management to the structural changes arising from climate-related
risks.
Management should develop and implement climate-related scenario
analysis frameworks in a manner commensurate to the institution's size,
complexity, business activity, and risk profile. These frameworks
should include clearly defined objectives that reflect the
institution's overall climate risk management strategies. These
objectives could include, for example, exploring the impacts of
climate-related risks on the institution's strategy and business model,
identifying and measuring vulnerability to relevant climate-related
risk factors including physical and transition risks, and estimating
climate-related exposures and potential losses across a range of
plausible scenarios. In the near term, a climate-related scenario
analysis framework can also assist the institution in identifying data
and methodological limitations and uncertainty in climate risk
management and informing the adequacy of its climate risk management
framework.
Climate-related scenario analyses should be subject to oversight,
validation, and quality control standards that would be commensurate to
their risk. Climate-related scenario analysis results should be clearly
and regularly communicated to all relevant individuals within the
institution, including an appropriate level of information necessary to
effectively convey the assumptions, limitations, and uncertainty of
results.
III. Management of Risk Areas
A risk assessment process is part of a sound risk governance
framework, and it allows boards and management to identify emerging
risks and to develop and implement appropriate strategies to mitigate
those risks. Boards and management should consider and incorporate
climate-related financial risks when identifying and mitigating all
types of risk. These risk assessment principles describe how climate-
related financial risks can be addressed in various risk categories.
The FDIC will elaborate on these risk assessment principles in
subsequent guidance.
A. Credit Risk
The board and management should consider climate-related financial
risks as part of the underwriting and ongoing monitoring of portfolios.
Effective credit risk management practices could
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include monitoring climate-related credit risks through sectoral,
geographic, and single-name concentration analyses, including credit
risk concentrations stemming from physical and transition risks. As
part of concentration risk analysis, management should assess potential
changes in correlations across exposures or asset classes. The board
and management should determine credit risk appetite and lending limits
related to these risks.
B. Liquidity Risk
The board and management should assess whether climate-related
financial risks could affect liquidity and, if so, incorporate those
risks into their liquidity risk management practices and liquidity
buffers.
C. Other Financial Risk
Management should monitor interest rate risk and other model inputs
for greater volatility or less predictability due to climate-related
financial risks. Where appropriate, management should include
corresponding measures of conservatism in their risk measurements and
controls. The board and management should monitor how climate-related
financial risks affect their institution's exposure to risk related to
changing prices. While market participants are still researching how to
measure climate price risk, the board and management should use the
best measurement methodologies reasonably available to them and refine
them over time.
D. Operational Risk
The board and management should consider how climate-related
financial risk exposures may adversely impact an institution's
operations, control environment, and operational resilience. Sound
operational risk management includes incorporating an assessment across
all business lines and operations, including third-party operations,
and considering climate-related impacts on business continuity and the
evolving legal and regulatory landscape.
E. Legal/Compliance Risk
The board and management should consider how climate-related
financial risks and risk mitigation measures affect the legal and
regulatory landscape in which the institution operates. This
consideration includes possible changes to legal requirements for, or
underwriting considerations related to, flood or disaster related
insurance. It also includes possible fair lending concerns if the
financial institution's risk mitigation measures disproportionately
affect communities or households on a prohibited basis such as race or
ethnicity.
F. Other Nonfinancial Risk
Consistent with sound oversight, the board and management should
monitor how the execution of strategic decisions and the operating
environment affect the financial institution's financial condition and
operational resilience as discussed in the strategic planning section.
The board and management should also consider the extent to which the
financial institution's activities may increase the risk of negative
financial impact from reputational damage, liability, or litigation,
and implement adequate measures to account for these risks where
material.
IV. Paperwork Reduction Act
The Paperwork Reduction Act of 1995 (44 U.S.C. 3501-3521) (PRA)
states that no agency may conduct or sponsor, nor is the respondent
required to respond to, an information collection unless it displays a
currently valid Office of Management and Budget (OMB) control number.
These draft principles do not revise any existing, or create any
new, information collections pursuant to the PRA. Therefore, the FDIC
is not making a submission to OMB.
V. Request for Comment
The FDIC welcomes feedback on all aspects of these draft
principles, including on the following questions. Among other uses, the
FDIC would consider responses in connection with developing any future
guidance on climate-related financial risks.
A. Applicability
Question 1: What additional factors, for example asset size,
location, and business model, should inform financial institutions'
adoption of these principles?
B. Tailoring
Question 2: How could future guidance assist a financial
institution in developing its climate-related financial risk management
practices commensurate to its size, complexity, risk profile, and scope
of operations?
C. General
Question 3: What challenges do financial institutions face in
incorporating these draft principles into their risk management
systems? How should the FDIC further engage with financial institutions
to understand those challenges?
Question 4: Would regulations or guidelines prescribing particular
risk management practices be helpful to financial institutions as they
adjust to doing business in a changing climate?
D. Current Risk Management Practices
Question 5: What specific tools or strategies have financial
institutions used to successfully incorporate climate-related financial
risks into their risk management frameworks?
Question 6: How do financial institutions determine when climate-
related financial risks are material and warrant greater than routine
attention by the board and management?
Question 7: What time horizon do financial institutions consider
relevant when identifying and assessing the materiality of climate-
related financial risks?
Question 8: What, if any, specific products, practices, and
strategies--for example, insurance or derivatives contracts or other
capital market instruments--do financial institutions use to hedge,
transfer, or mitigate climate-related financial risks?
Question 9: What, if any, climate-related financial products or
services--for example, ``green bonds,'' derivatives, dedicated
investment funds, or other instruments that take climate-related
considerations into account--do financial institutions offer to clients
and customers? \10\ What risks, if any, do these products or services
pose?
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\10\ ``Green bonds'' generally refer to fixed-income securities,
the proceeds of which are earmarked for environmentally beneficial
investment.
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Question 10: How do financial institutions currently consider the
impacts of climate-related financial risk mitigation strategies and
financial products on households and communities, specifically LMI and
other disadvantaged communities? Should the agencies modify existing
regulations and guidance, such as those associated with the Community
Reinvestment Act, to address the impact climate-related financial risks
may have on LMI and other disadvantaged communities?
E. Data, Disclosures, and Reporting
Question 11: What, if any, specific climate-related data, metrics,
tools and models from borrowers and other counterparties do financial
institutions need to identify, measure, monitor, and control their own
climate-related financial risks? How do financial institutions
currently obtain this information? What gaps and other concerns are
there with respect to these data, metrics, tools or models?
Question 12: How could existing regulatory reporting requirements
be augmented to better capture financial
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institutions' exposure to climate-related financial risks?
F. Scenario Analysis
Question 13: Scenario analysis is an important component of climate
risk management that requires assumptions about plausible future states
of the world. How do financial institutions use climate scenario
models, analysis, or tools and what challenges do they face?
Question 14: What factors are most salient for the FDIC to consider
when designing and executing scenario analysis exercises?
Federal Deposit Insurance Corporation.
By order of the Board of Directors.
Dated at Washington, DC, on March 29, 2022.
James P. Sheesley,
Assistant Executive Secretary.
[FR Doc. 2022-07065 Filed 4-1-22; 8:45 am]
BILLING CODE 6714-01-P