The report urges financial regulatory agencies to consider requiring companies to disclose their climate-related financial risks. While it does not mention subjecting Wall Street banks to “stress tests” like those required since the mortgage crisis, it does recommend that bank regulators use “scenario analysis” as a tool for assessing climate-related financial risks.
Treasury Department officials said the idea of scenario analysis was similar to that of stress tests. A senior Treasury official, who spoke on the condition of anonymity, said in an interview that the FSOC report “for the first time clearly states that climate change is an emerging and increasing threat to financial stability and puts together a set of actions.” He called the new recommendations “groundbreaking.”
President Biden mandated the report in a May 20 executive order on climate-related financial risk. While the report was not due until mid-November, FSOC may have issued it early in a bid to give U.S. negotiators more credibility at a United Nations climate summit in Scotland next month, particularly as Democrats in Congress scramble to salvage climate provisions in their troubled tax-and-spending package.
FSOC is a regulatory body chaired by Treasury Secretary Janet L. Yellen and composed of 10 financial regulators, such as the Office of the Comptroller of the Currency, the Securities and Exchange Commission and the Federal Reserve. The council also includes another five nonvoting members. It was created by the Dodd-Frank Act in the wake of the 2008 financial crisis to identify emerging risks to the economy.
Climate activists have argued that while disclosure of climate-related risks and stress tests are necessary first steps toward preventing a climate-fueled economic crash, the measures are inadequate on their own. Advocates have called on Yellen to curb or discourage lending from banks to companies that produce large quantities of planet-warming carbon emissions.
Evergreen Action, an environmental group, has also urged FSOC to impose new climate-related capital requirements, which would force banks to maintain greater amounts of capital when they hold fossil fuel assets that the group sees as risky.
“This report puts Wall Street on notice. The report acknowledges in no uncertain terms that climate change is threatening the financial stability of the United States,” Becca Ellison, deputy policy director at Evergreen Action, said in an interview.
“But simply studying the problem is not enough,” she said. “Financial regulators need to be addressing the drivers of climate-related financial risk, which are fossil fuels and the financing of fossil fuels.”
Ben Cushing, campaign manager of the Sierra Club’s Fossil-Free Finance campaign, said in a statement that while the report contains positive steps, “it’s also a missed opportunity to recommend actions that actually reduce climate risk and limit Wall Street’s toxic investments in the fossil fuels that are driving the crisis.”
Another senior Treasury official, who also spoke on the condition of anonymity, stressed that the report marked the beginning of FSOC’s consideration of climate-related financial risks, not the end.
“This report is a very significant step. But it’s also the first step, and we expect further action going forward,” the official said on a call with reporters Thursday. “This is like the starting gun going off for the U.S. financial system.”
Other experts on the financial system’s stability said that Dodd-Frank gives FSOC the power to make specific recommendations to agencies under its umbrella, but the report Thursday did not make any specific recommendations. The Dodd-Frank law also allows FSOC to impose “new or heightened regulatory standards” on banks and non-bank financial firms.
But the Treasury official said imposing recommendations was “an involved process” necessitating congressional oversight. Moreover, the SEC is widely expected to soon issue its own regulations on companies’ disclosures of climate-related liabilities and risks. Those could include the disclosure of greenhouse gas emissions and vulnerability to potential new climate regulations.
The FSOC report also calls for the creation of a new staff-level committee, the Climate-related Financial Risk Committee (CFRC), within 60 days of its publication. The new committee will identify priority areas for finding climate-related risks to the financial system and will update the council at least semiannually.