ICBA Statement on New York’s Proposed Climate Risk Guidance

Washington, D.C. (Dec. 21, 2022) — Independent Community Bankers of America (ICBA) President and CEO Rebeca Romero Rainey issued the following statement on New York State Department of Financial Services proposed guidance on climate risk.

“Today’s New York State Department of Financial Services proposed guidance on climate risk contains no exemptions for community banks, ensuring it would subject these institutions and the communities they serve to new and expensive regulatory burdens. Community banks have decades of experience managing concentration risks and responding to extreme weather events and natural disasters in their communities — meaning new, onerous, and expensive climate risk management frameworks are counterproductive.

“Regulators should not impose climate risk regulations on community banks for the following reasons.

• Current risk management practices protect community banks from climate-related financial risks, as evidenced by the absence of community bank failures following severe weather events.

• The lack of empirical data points to another concern with these proposals — that the government’s ultimate motive is to choke off legal but disfavored businesses and industries from the financial system. If climate risk proposals are not intended to choke off specific industries from the financial system, regulators should expressly state there is no supervisory expectation that banks de-risk legal but climate-disfavored industries.

• Before contemplating new policies, agencies should first conduct studies and gather empirical data to determine the extent to which climate-related financial risks affect the safety, soundness, and stability of community banks and the financial system.

“Resiliency is central to community banks’ business model, with their longstanding underwriting and insurance practices addressing the impact of severe weather events and natural disasters since the early 19th century. The NYDFS and other regulators should reconsider their climate risk proposals and their adverse effects on local communities.”

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 more than $5.8 trillion in assets, over $4.8 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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