Climate Finance Policy Engagement Analysis
Climate Lobbying Overview: Bank of America appears to be somewhat engaged on climate policy, stating topline support for climate disclosure policies and government action to decarbonize the economy.
Top-Line Messaging on Climate-Related Financial Policy: In its 2023 Environmental and Social Risk Policy Framework, Bank of America stated support for the Paris Agreement goal to limit temperature rise to well below 2C. In its 2023 TCFD Report, Bank of America appeared to support regulatory action on climate-related financial policy.
Position on Regulated Corporate Climate Disclosure: In its 2024 Sustainability Report Bank of America stated support for regulating corporate climate risk and GHG emissions disclosure. After the SEC released its proposed climate disclosure rule in March 2022, Bank of America was quoted in Reuters supporting the proposal, calling it “constructive and headed in the right direction,” while cautioning against immediate Scope 3 disclosure requirements. However, in its comment letter to the SEC in 2022, Bank of America outlined major exceptions to its support for the disclosure rule, objecting to several aspects of the proposal including the financial statement metrics and some qualitative risk disclosure requirements. In a July 2022 letter, Bank of America outlined similar objections to the International Sustainability Standards Board’s (ISSB) draft climate disclosure standards. In August 2022 comments to the European Financial Reporting Advisory Group on proposed European Sustainability Reporting Standards (ESRS), Bank of America opposed a double materiality approach to reporting and argued against the level of detail of the proposed requirements. The company again objected to the proposed ambition of the Standards in July 2023 comments to the Commission.
CEO Brian Moynihan has voiced his support for the ISSB disclosure standards in a January 2023 interview with CNBC, a June 2023 statement to Politico, and February 2024 remarks at the International Financial Reporting Standards (IFRS) Sustainability Symposium.
Position on Incorporating Climate Factors Into Investor Duties: According to Florida lobbying disclosures, in 2023, Bank of America engaged on HB 3, legislation to prohibit the use of ESG factors in state and local investment decisions and procurement processes. Details of Bank of America’s engagement are unclear.
Position on Incorporating Climate Factors Into Risk Management/Prudential Regulation: A 2022 memo shows that Bank of America, as constituents of the Bank Policy Institute, met with the Office of the Comptroller of the Currency to discuss “challenges” with the Office’s draft principles for climate-related financial risk management. Bank of America has not disclosed details of this meeting or outlined its position on climate-related financial risk regulation. In its 2024 Sustainability Report Bank of America described efforts by regulators to incorporate climate risk into prudential regulation, but took no clear position on these efforts.
Position on Real Economy Climate Policy: In its 2023 Environmental and Social Risk Policy Framework, Bank of America stated support for a carbon tax. In its 2024 Sustainability Report, it outlined its “continuously stated support” for a price on carbon. According to the EU Transparency Register, in 2022 Bank of America met with representatives from the European Commission to discuss EU climate policy and carbon pricing, but details of this meeting are unclear.
Position on Energy, Industry, and Land Transitions: Bank of America appears generally supportive of the transition of the energy mix. In its 2024 Sustainability Report the bank committed to lobby, directly and indirectly, in support of an “orderly transition to Net Zero.” In the same report, Bank of America supported various policy measures to decarbonize the economy, including increased use of Sustainable Aviation Fuels (SAF) and US Inflation Reduction Act (IRA) incentives to drive SAF production, government policies and investments to decarbonize transportation, and permitting reform in order to support a transition to renewables. In 2022 comments on the implementation of the IRA’s clean energy tax incentives, Bank of America took a generally neutral stance on the policy but in one comment suggested that energy storage technology need not limit its use of energy from sources other than solar or wind to under 25% to qualify for investment tax credits. Additionally, a 2023 letter submitted to the Municipal Advisory Council of Texas shows evidence of Bank of America’s continued support for investing in fossil fuels.
Industry Association Governance: Bank of America has disclosed a list of its key industry association memberships, but has not disclosed an account of its industry associations' policy positions and engagement activities, including the US Chamber's opposition to climate disclosure policies in California and at the SEC or Bank Policy Institute's engagement on climate-related risk principles with federal financial regulators. Additionally, it appears to omit some groups including the Greater Boston Chamber of Commerce and the Business Council of Australia.
InfluenceMap collects and assesses evidence of corporate climate policy engagement on a weekly basis, depending on the availability of information from each specific data source (for more information see our methodology). While this analysis flows through to the company’s scores each week, the summary above is updated periodically. This summary was last updated in Q4 2024.