American Bankers Association (ABA)

InfluenceMap Score
Performance Band
Organisation Score
Washington DC, United States
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Sustainable Finance Lobbying Overview: The American Bankers Association (ABA) has been generally unsupportive of sustainable finance policy in the US, engaging most actively against efforts to regulate corporate ESG disclosure, integrate ESG into fiduciary duties, and incorporate climate risk into prudential regulation.

Top-Line Messaging on Sustainable Finance Policy: ABA appears to recognize the risk climate change poses to the financial system. A 2021 joint paper on ABA’s website states support for urgent action to tackle climate change and deliver the goals of the Paris Agreement, but emphasizes the importance of private sector innovation and market-based solutions in doing so. In 2022, ABA sent a letter to US banking regulators that cautioned the regulators against using banks as "proxies to effectuate environmental or other social policy goals," specifically referring to ESG guidance and regulatory proposals. CEO Rob Nichols has stated opposition to regulatory action on ESG issues for banks.

Position on Regulated Corporate ESG Disclosure: ABA appears unsupportive of regulated corporate ESG disclosure. In response to the SEC’s request for comment on climate disclosures in 2021, ABA voiced support for a climate risk disclosure regime but advocated for a flexible approach and a significant transition period. ABA has not supported the SEC's 2022 proposed climate disclosure rule, questioning the value of the proposal in a May 2022 podcast and urging the Commission to "significantly revise - or withdraw altogether and repropose" the rule in a June 2022 blog post and comment letter. In August 2022, ABA sent a letter to the California State Assembly in opposition to SB 260, a corporate greenhouse gas disclosure bill. The bill subsequently did not pass. Also in 2022, ABA outlined several objections to the International Sustainability Standards Board’s proposed climate disclosure standards, which are likely to inform government policy.

Position on Incorporating ESG Factors Into Investor Duties: ABA appears to have a mixed position on incorporating ESG factors into investor duties. In 2021, ABA stated opposition to an Office of the Comptroller of the Currency (OCC) rule that sought to limit ESG investing, calling it “ill-advised.” In 2020, ABA voiced opposition to Department of Labor (DoL) rules that would limit fiduciaries’ ESG investing and voting on ESG issues. However, in comments on the 2021 proposed reversal of these rules, ABA asked the DoL to alter and remove references to ESG considerations in rule language. In a letter to the DoL in 2022, ABA did not support regulatory action to require fiduciaries to consider climate risk in retirement plan decision-making and contested the idea that climate risks pose a threat to retirement savings.

Position on Incorporating ESG Factors Into Risk Management/Prudential Regulation: ABA has taken negative positions toward incorporating ESG factors into risk management and prudential regulation. ABA has voiced opposition to prudential regulation that tries to “regulate other industries indirectly” or carry out “environmental or other social policy goals.” In response to the OCC’s and the Federal Deposit Insurance Corporation’s (FDIC) proposed principles for climate-related financial risk management in 2022, ABA did not support regulatory action on climate-related financial risk, calling it “premature.” Similarly, in 2022 comments to the Basel Committee for Banking Supervision, ABA advocated for a less ambitious approach than outlined in the Committee’s Principles for Effective Management and Supervision of Climate-related Financial Risks.

Transparency: ABA has uploaded the letters it sends to regulators on its website, but some information is restricted to members only. ABA discloses board membership but not general membership.

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