Supervisory and Regulatory Approaches to Climate-related Risks: FSB, OCC and FDIC

Even as regulatory authorities and international standard-setters work to establish consistency across climate-related risk measurement and management frameworks, financial services companies must look to their specific regulatory authorities for direction and guidance. Jurisdictional differences are expected. The FSB guidance and recommendations align with recent draft principles released from the OCC and FDIC, which signal that the financial services regulators’ expectations will go beyond the SEC’s proposed disclosure requirements and are likely to fall under their existing safety and soundness, resiliency, and enterprise risk management authorities. They note they intend to issue subsequent guidance that would distinguish roles and responsibilities for boards and management; this follows earlier OCC guidance on questions boards should be asking about climate change and financial risks. Going forward, financial services companies should expect the U.S. regulators to set their own course, informed by international frameworks and regulations; they will focus on climate-related governance, risk management, and scenario analysis, inclusive of higher expectations in areas like stress test, portfolio/sector analysis, due diligence, and integration across all risk pillars.