ARTICLE
15 November 2021

OCC Asks Bank Boards To Better Manage And Report Climate Risk

CW
Cadwalader, Wickersham & Taft LLP

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Cadwalader, established in 1792, serves a diverse client base, including many of the world's leading financial institutions, funds and corporations. With offices in the United States and Europe, Cadwalader offers legal representation in antitrust, banking, corporate finance, corporate governance, executive compensation, financial restructuring, intellectual property, litigation, mergers and acquisitions, private equity, private wealth, real estate, regulation, securitization, structured finance, tax and white collar defense.
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.
United States Finance and Banking
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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.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

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