January 23, 2022

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OCC Asks Bank Boards to Better Manage and Report Climate Risk

Acting Comptroller of the Currency Michael J. Hsu urged large bank boards to begin assessing how they are managing and reporting climate risks, given the potential impact that physical and transitional risks can have on a bank's portfolios.

Mr. Hsu offered five questions for large banks to consider, including:

  1. "What is our overall exposure to climate change?"

  2. "Which counterparties, sectors or locales warrant our heightened attention and focus?"

  3. "How exposed are we to a carbon tax?"

  4. "How vulnerable are our data centers and other critical services to extreme weather?"

  5. "What can we do to position ourselves to seize opportunities from climate change?"

The OCC recommended that bank boards include "top-down" and "bottom-up" analyses of their exposures to climate change. The OCC stated that it will issue an expanded framework of guidance for large banks on climate risk management by the end of the year.

As previously covered, the OCC took additional steps to address climate change by appointing Darrin Benhart as the agency's Climate Change Risk Officer and joining the Network of Central Banks and Supervisors for Greening the Financial System.

© Copyright 2022 Cadwalader, Wickersham & Taft LLPNational Law Review, Volume XI, Number 313
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