Tag Archives: Climate Change

Letters and Statements: OMB Should Approve Climate Data Call to Equip FIO and Other Financial Regulators with Information on How Climate Change is Affecting Homeowners Insurance Coverage

Americans for Financial Reform Education Fund submitted a comment letter to the Office of Management and Budget (OMB) for its approval, without delay, of the Department of the Treasury’s Federal Insurance Office (FIO) final proposed “Climate-Related Financial Risk Data Collection for U.S. Homeowners Multi-Peril Underwriting

Letters to Regulators: NCUA Budget for 2024-2025 Should Account for Climate-Related Financial Risk to Credit Unions and Consumer Protection Needs

Americans for Financial Reform Education Fund led and submitted a comment letter, to the NCUA on the agency’s draft 2024-2025 budget. The letter was endorsed by Green America, the National Coalition for Asian Pacific American Community Development, the National Fair Housing Alliance, New York Communities

Letters to the Regulators: Letters to the Financial Stability Oversight Council in Support of Increased Supervision of Nonbank Companies and Revising the Analytic Framework for Assessing Financial Stability Risk

AFREF submitted comment letters to the Financial Stability Oversight Council (FSOC) on two proposals that would strengthen its toolbox for addressing threats to financial stability, including those related to climate change, and make it easier to designate nonbank companies like asset managers and insurance companies as systemically important institutions that need enhanced regulation by the Federal Reserve Board.

The letters detail how threats to financial stability from nonbank financial institutions are growing, and it encourages FSOC to quickly strengthen and finalize its proposals to be able to respond effectively and proactively to emerging risks. Many nonbank financial institutions already face heightened stress from large climate-related shocks, including several major insurers’ recent decisions to withdraw coverage from many states and zip codes. Insurance companies, asset managers, private equity firms, and other nonbank financial institutions are also creating significant risks to the financial system through their insured or financed emissions — risks that are often forced upon other financial institutions and consumers who will struggle to manage them.

Letters to the Regulators: Letter to PCAOB Supporting Proposed Audit Standards to Report Noncompliance with Laws and Regulations, Including Climate Regulations

AFREF joined Public Citizen in a comment urging PCAOB to strengthen and swiftly finalize its proposed updated audit standards around reporting noncompliance with laws and regulations and identifying risks of material misstatement in financial statements. Climate-related accounting fraud is on the rise, and many companies are misrepresenting their financial position by underestimating their asset retirement obligations and environmental liabilities, and failing to substantiate public climate commitments in their financial statements and SEC filings. 

The proposed regulatory updates from PCAOB would strengthen auditors’ responsibilities to identify and report these types of misstatements and fraud and provide a significant benefit to investors by catching costly noncompliance issues early before they harm financial performance, and to the public by deterring corporate law-breaking and noncompliance.

Letters to Regulators: CFPB Should Finalize Residential PACE Rule and Develop Consumer Protections for Emerging Green Lending Products

Americans for Financial Reform Education Fund submitted a comment letter, endorsed by 20 partner organizations, to the Consumer Financial Protection Bureau (CFPB)’s proposed rule on residential Property Assessed Clean Energy (PACE) financing.  The letter urges the CFPB to finalize the residential PACE rule swiftly to

Letters to Regulators: NCUA Should Bolster Staff Capacity, Training, Tools, Research & Analysis, and Guidance on Climate-related Financial Risk

Americans for Financial Reform Education Fund submitted a comment letter endorsed by The Greenlining Institute and Public Citizen, in response to the National Credit Union Administration (NCUA)’s request for information on climate-related financial risk. The letter urges the NCUA to proceed with critical next steps

Letters to Regulators: EPA Should Continue to Develop Greenhouse Gas Reduction Fund Guidance that Delivers Tangible Benefits to Low-Income and Disadvantaged Communities Across the Country

May 12, 2023 Americans for Financial Reform Education Fund (AFREF) submitted an environmental justice advocates comment letter signed by Public Citizen and WE ACT for Environmental Justice to the Environmental Protection Agency (EPA) on its Implementation Framework for the Greenhouse Gas Reduction Fund.  The Implementation