Thirty-nine State Treasurers, Auditors, and Attornies General submitted the following comments in response to the Office of the Comptroller of the Currency (“OCC”)’s request for feedback regarding Risk Management: Principles for Climate-Related Financial Risk Management for Large Banks (“Proposed Principles”). We requested that the OCC not adopt the Proposed Principles.

Under the OCC proposal, banks will be required to monitor and respond to climate-related risk even when immaterial, to undertake costly scenario analyses that are not required even for other material risks, and to labor under a series of requirements that have no role where other risks are concerned.

Read the letter to the Office of the Comptroller of the Currency here.

https://sto.idaho.gov/Portals/0/xBlog/uploads/2022/2/22/2022-02-14-Comment-to-OCC-Principles-for-Climate-Related-Financial-Risk-Management-for-Large-Banks.pdf