ICBA and 44 state banking groups wrote to the FDIC to express concerns that the agency’s proposed climate risk management framework for large banks could “choke off” lawful but climate-disfavored industries from the banking system. ICBA also expressed concern that the framework would eventually, and inappropriately, “trickle down” to community banks.
"Banks should have the ability to lend to any consumer or corporate citizen who is creditworthy and engaged in lawful activity, without fear of political or regulatory retribution," the coalition said.
Recommendations: ICBA and the state banking group urged the FDIC to review its 100-year bank data and:
Conduct further studies and gather empirical data to better understand the efficacy of the current risk management framework and practices in managing climate-related financial risk; and
Address any specific gaps in the current framework and the degree that climate-related risk may or may not threaten the safety and soundness of the financial system.