Sustainable Finance Lobbying Overview: Bank of America’s engagement on sustainable finance policy has centered primarily on corporate ESG disclosure regulations, for which it has stated top-line support while objecting to specifics of policies.

Top-Line Messaging on Sustainable Finance Policy: Bank of America has advocated for action to achieve zero-carbon economies before 2050 and stated its support for the Paris Agreement’s goal to keep global temperature rise to well below 2C. In April 2021, Bank of America joined the Net Zero Banking Alliance. Bank of America has emphasized its ability as a global financial institution to “mobilize and deploy capital to address climate change,” but in 2020, CEO Brian Moynihan advocated for continued funding for oil and gas companies. In its April 2022 Approach to Zero commitment, Bank of America appeared to support regulatory action on sustainable finance.

Position on Regulated Corporate ESG Disclosure: Bank of America has stated support for regulating corporate ESG disclosure, asserting that voluntary disclosure efforts are insufficient. After the SEC released its proposed climate disclosure rule in March 2022, Bank of America supported 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 June 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 July 2022, Bank of America outlined similar objections to the International Sustainability Standards Board’s draft climate disclosure standards. In August 2022 comments to the European Financial Reporting Advisory Group on proposed European Sustainability Reporting Standards, Bank of America opposed a double materiality approach to reporting and argued against the level of detail of the proposed requirements.

Position on Incorporating ESG Factors Into Risk Management/Prudential Regulation: In 2022, Bank of America announced that it had joined the Risk Management Association’s Climate Risk Consortium, and that the Consortium was engaging with regulators and policymakers on climate-related risk management and prudential regulations for banks, but details of this engagement are unclear. A memo from the SEC 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 publicized details of this meeting or outlined its position on climate-related financial risk regulation.

Industry Association Governance: Bank of America has disclosed some of its trade association memberships with little detail of the sustainable finance policy positions of these organizations. The disclosure omits membership of some associations including the Association for Financial Markets in Europe and the Japanese Bankers Association.