On December 16, 2021, the Office of the Comptroller of the Currency (“OCC”) issued draft principles (the “Proposal”) on the identification and management of climate-related financial risks by OCC-supervised banks with more than $100 billion in total consolidated assets (“covered banks”). The Proposal is intended to provide a high-level framework for the safe and sound management of climate-related financial risks by covered banks and will serve as the basis for more detailed guidance applicable to all OCC-supervised banks. Feedback on the Proposal is due by February 14, 2022; the OCC has indicated that subsequent guidance will incorporate the feedback received on the Proposal and distinguish the roles and responsibilities of boards of directors and management.

Click here to read our Ten Things to Know about the Proposal.