ICBA Statement on Interagency Climate Risk Guidance for Large Banks

Washington, D.C. (Oct. 24, 2023)—Independent Community Bankers of America (ICBA) President and CEO Rebeca Romero Rainey issued the following statement on today’s release of interagency guidance for climate-related financial risk management for large financial institutions.

“While ICBA appreciates that today’s interagency climate related financial risk management guidance applies only to institutions with $100 billion or more in assets, we are troubled by the impact these principles may ultimately have on community banks, and we object to vague language in this document describing all financial institutions.

“ICBA remains concerned that the true aim of the principles is to choke off legal but disfavored industries from the financial system, and that community banks may also be expected to comply with today’s large bank guidance. The agencies must ensure their novel efforts to impose supervisory expectations about climate risk through guidance do not adversely affect community banks, their customers, and the communities they serve.

“Community banks have decades of experience managing concentration risks and responding to extreme weather events and natural disasters in their communities — as noted by FDIC Chairman Martin Gruenberg — so any climate risk management frameworks, best practices, or other guidance that is aimed at, or that trickles down to, community banks would be counterproductive.

“ICBA will continue working with policymakers to ensure regulators do not impose climate risk regulations on community banks.”

About ICBA

The Independent Community Bankers of America® creates and promotes an environment where community banks flourish. ICBA is dedicated exclusively to representing the interests of the community banking industry and its membership through effective advocacy, best-in-class education, and high-quality products and services.

With nearly 50,000 locations nationwide, community banks constitute roughly 99 percent of all banks, employ nearly 700,000 Americans and are the only physical banking presence in one in three U.S. counties. Holding nearly $5.9 trillion in assets, over $4.9 trillion in deposits, and more than $3.5 trillion in loans to consumers, small businesses and the agricultural community, community banks channel local deposits into the Main Streets and neighborhoods they serve, spurring job creation, fostering innovation and fueling their customers’ dreams in communities throughout America. For more information, visit ICBA’s website at www.icba.org.

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