Climate Risk Guidance

Banks face a wide range of emerging risks. Take, for example, the risk that a breakthrough in quantum computing could suddenly pose to banks’ ability to encrypt financial transactions or customer information. Or the risk that artificial intelligence could have on banks’ cybersecurity. Or the risk that continuing federal deficits could lead to higher interest rates or even downgrades of U.S. debt.

So, if we replaced every reference in the guidance to “climate risk” or “climate-related financial risk” with a more encompassing term like “emerging risk,” I could perhaps vote for it. We could even define “emerging risk” to include “climate-related financial risk” such that the guidance would have the same legal effect, and I could still be open to supporting it.

But this guidance’s singular focus on just this one possible emerging risk among many exposes the real intent and effect. This guidance positions the U.S. bank regulators to follow the lead of their European counterparts in pushing banks to facilitate a transition to a lower carbon economy. This is all about getting bank regulators involved in the pricing and allocation of capital.

Policy decisions like this should be left to our elected leaders. Our involvement will just further politicize the bank regulators and distract us from our safety and soundness mandate.