Under the Proposed FDIC Principles, 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. This special concern for and attention to climate-related risks is irrational. There is no evidence that such risks stand above other dangers to the banking system or that banks need prompting to consider such risks. Climate risk does not need special treatment.

Read the full letter here.