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This document is intended to be a guide as you formulate a comment letter in response to the FDIC’s request for comment on its statement of principles for climate-related financial risk management for large financial institutions.
Your letter does not need to be lengthy or address every component of the request, but it should include details about your bank and your community and should articulate your unique concerns about the proposal.
Introduction
A typical comment letter begins with an introductory paragraph that provides:
The reason that you are writing to the FDIC (e.g., “I am writing regarding the FDIC’s request for comment on its statement of principles for climate-related financial risk management for large financial institutions,” or “I am submitting this letter in response to the FDIC’s request for comment on its statement of principles...”)
A brief background of your bank, your role, and the community you serve. Include anything that makes your bank special or unique (e.g., “I am the President and CEO of Bank of Anytown, a $400 million community bank located in Anytown, US… we primarily provide agricultural loans and are the only bank with a physical branch presence in Anytown County.”)
Your abbreviated position on the proposed rule (e.g., “I am concerned that the FDIC may, in the future, apply this climate-related financial risk management to community banks,” or “The proposed framework for managing climate-related financial risk management for large banks will negatively impact my community.”)
Comment on specific sections or provisions
After the introduction, your letter should concentrate on the specific provisions on the request on which you would like to comment. The analysis below can be used as a guide to help you identify issues that you might want to address in your letter.
Conclusion
You can conclude your letter by thanking the FDIC for the opportunity to submit comments on the proposed framework. You may also thank the FDIC for limiting its proposal to banks with more than $100 billion in assets and encourage the FDIC to conduct outreach with community bankers to better understand why this proposal should never apply to community banks.
When you have finished drafting your letter, copy and paste it into ICBA’s Grassroots Center, where it will be sent directly to the FDIC.
Comments are due by June 3, 2022.