Financial Services Forum

Sector

Financials

Headquarters

District of Columbia, United States

Official Website

fsforum.com

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.

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InfluenceMap Score for Climate Finance Policy Engagement

N/A

Performance Band

N/A

Organization Score

2%

Engagement Intensity

Primary Evidence

All primary evidence used to inform the analysis of Financial Services Forum can be found in the two tabs below below. In the first tab, hyperlinks in each cell of the matrix provide access to evidence collected on Financial Services Forum's direct policy engagement activities. The second tab provides a record of any links between Financial Services Forum and the Industry Associations stored in the LobbyMap database.

DATA SOURCES
QUERIES
Main Web Site

Main Web Site

Corporate Media

Corporate Media

CDP Responses

CDP Responses

Direct Consultation with Governments

Direct Consultation with Governments

Media Reports

Media Reports

CEO Messaging

CEO Messaging

Financial Disclosures

Financial Disclosures

Reforming the financial sector: Does the organization support the need for systemic reforms to deliver a sustainable financial system?

NSNSNANSNSNSNA

Climate Science Stance: Does the organization support a science-based response to the climate crisis?

01NANSNSNSNA

Need for climate policy: Does the organization support the need for climate-related finance regulation?

00NANSNSNSNA

Disclosures: Does the organization support regulated corporate climate disclosure?

NS0NA-1NSNSNA

Taxonomies: Does the organization support a taxonomy?

NSNSNANSNSNSNA

Financial Products and Ratings: Does the organization support climate standards, labels and/or benchmarks for financial products and policy on ESG ratings?

NSNSNANSNSNSNA

Investor Duties: Does the organization support policy to incorporate climate factors into investor duties?

NSNSNANSNSNSNA

Prudential Regulation: Does the organization support policy to incorporate climate factors into risk management/ prudential regulation?

NS-1NA-1NS0NA

Real Economy Climate Regulations: the organization support real economy climate policy and regulation?

NSNSNANSNSNSNA

Energy, Industry and Land Transitions: Does the company support energy, industry and land transitions as required by the IPCC?

NSNSNANSNSNSNA

Disclosure on Lobbying: Is the organization being transparent about their positions on climate legislation and policy?

2NSNANSNSNSNS

Disclosure on Relationships: Are companies being transparent about their business associations which may impact climate debate and policy?

2NSNANSNSNSNS