OCC Seeks Public Feedback on Principles for Climate-Related Financial Risk Management for Large Banks

Sullivan & Cromwell LLP - December 21, 2021

On December 16, 2021, the Office of the Comptroller of the Currency (OCC) released draft Principles designed to provide large OCC-regulated institutions—national banks, federal savings associations and federal branches or agencies of foreign banking organizations (collectively referred to as “banks”) with over $100 billion in total consolidated assets—with a high-level framework for the safe and sound management of exposures to climate-related financial risks consistent with existing OCC rules and guidance. The OCC Principles outline six key aspects of climate-related financial risk management and offer risk assessment principles for incorporating climate-related financial risks in various traditional risk categories. The OCC is soliciting public feedback on the Principles to inform additional guidance on climate-related financial risks.
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