Climate Finance Policy Engagement Analysis
Climate Lobbying Overview: The Financial Services Forum appears to have a somewhat limited focus on climate-related issues for the financial sector, primarily engaging on climate-related risk management guidance and regulation.
Top-Line Messaging on Climate-Related Finance Policy: The Financial Services Forum has limited top-line messaging on climate issues, especially in recent years. Its webpage on “combatting climate change” is no longer accessible.
Position on Regulated Corporate Climate Disclosure: In comments to the Securities and Exchange Commission (SEC) in June 2022, the Financial Services Forum outlined several objections to the Commission’s proposed climate disclosure rule. The Forum requested that financial statement metrics disclosures be removed and called mandatory Scope 3 emissions disclosure “premature,” warning about the adverse effects the proposal could have on capital markets, lending activity, and corporate emissions reduction target-setting. The Forum met with the SEC in September 2022 to further discuss concerns about “burden and cost” of the proposed rule, but a detailed account of this meeting is unavailable.
Position on Incorporating Climate Factors into Risk Management/Prudential Regulation: The Financial Services Forum has taken a skeptical approach to policies to incorporate climate factors into prudential regulation. In comments to the Office of the Comptroller of the Currency (OCC) in February 2022, the Forum supported the OCC’s efforts to develop climate-related financial risk management guidance but advocated for flexibility and phase-in of scenario analyses. In comments to the Federal Deposit Insurance Corporation in June 2022 the Forum opposed a requirement to consider the impacts of risk management on broader aspects of the economy, and in comments to the Federal Reserve in 2023 the Forum outlined concerns with “overly prescriptive” board and management requirements for management of climate risk. In 2024 comments, the Forum outlined several objections to the Basel Committee’s proposed treatment of climate disclosures, asserting that banks' climate strategy, emissions, and physical risk exposure are outside the scope of Pillar 3 disclosures, which are intended to address financial risk and capital adequacy.