The Consumer Federation of America (CFA) submitted comments to the Office of the Comptroller of the Currency (OCC) on its draft principles designed to support the identification and management of climate-related financial risks by banks with over $100 billion in assets. The comments stressed the need  for legislative and administrative action to address the existential threats of climate change and the resulting serious economic, environmental, and public health consequences.

The comments stress that climate change presents substantial risks to banks, our financial system, and our economy, and many banks will benefit from clear, holistic guidance on assessing those risks. Low- and moderate- income (LMI) consumers, communities of color, and other financially vulnerable Americans are especially susceptible to the effects of climate change and climate-related financial risks, and CFA urged the OCC to pay particular attention to these consumers. CFA further recommended enacting mandatory requirements for considering climate-related financial risk, requiring banks to divest from climate change exacerbating projects, and encouraging banks to gather adequate expertise to address climate related financial risk.

CFA also joined onto coalition comments that focused on fair lending concerns.