ICBA response to New York climate proposal making news

ICBA’s pushback against New York State Department of Financial Services proposed guidance on climate risk is making headlines.

Making News: Politico Morning Money cited ICBA’s statement that the proposal contains no exemptions for community banks. Separately, American Banker reported ICBA’s criticism of the proposal for subjecting community banks to the same overly burdensome and costly guidance as the state’s largest institutions.

Overview: The newly issued proposed guidance—which has a March 21 comment deadline—contains sweeping expectations about how New York State-regulated banks should monitor and control their material climate-related financial risks.

ICBA Response: In a national news release, ICBA said the NYDFS and other regulators should reconsider their climate risk proposals and their adverse effects on local communities. ICBA strongly opposes climate risk regulation of community banks and has told policymakers that any trickle-down effect of large bank regulation in this area will stifle innovation and create barriers to serving consumers and small businesses.

ICBA Advocacy: ICBA recently expressed concerns with the FDIC and OCC climate risk proposals for larger institutions, noting they could ultimately apply to community banks. It has also said the SEC’s climate risk plan—which also includes no exemptions for smaller institutions—would discourage financial institutions from doing otherwise lawful business and participating in the public capital markets.