ICBA to OCC: Avoid One-Size-Fits-All Climate Principles

Washington, D.C. (Feb. 15, 2022) — The Independent Community Bankers of America (ICBA) applauded the Office of the Comptroller of the Currency for tailoring its proposed climate-related financial risk management principles to banks over $100 billion in assets, though the association expressed concerns that examiners could eventually apply the framework to community banks.

“ICBA applauds the OCC for recognizing its draft principles for climate-related financial risk management should be appropriately tailored to bank size, complexity, risk profile and operations,” ICBA President and CEO Rebeca Romero Rainey said today. “A one-size-fits-all approach to bank regulation is rarely, if ever, appropriate—and climate-related financial risk management is no exception.”

In its comment letter to the OCC, ICBA also:

• Expressed concern that the true aim of the proposal may be to effectuate Operation Choke Point by cutting off legal but disfavored industries from the financial system.
• Noted the OCC published its principles without first conducting any studies or gathering empirical data to determine the extent to which climate-related financial risks affect the safety, soundness, and stability of banks and the financial system.
• Said current risk management practices adequately protect community banks from climate-related financial risks.
• Encouraged regulators to work together on a harmonized approach to climate principles, study the extent to which climate risks pose significant safety and soundness risks, hold community bank outreach meetings and exercises, and expressly inform examiners that banks are not expected to choke off legal customers or industries.
• Opposed applying any climate-related financial risk framework to community banks with less than $100 billion in assets.
• Encouraged the agency to consider incentive-based solutions to address climate change, such as Community Reinvestment Act credit for financing activities that address climate change.

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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