This bill voids the interagency guidance on climate-related financial risk management for large financial institutions and prohibits the issuing of substantially similar guidance.
Troy Balderson
Representative
OH-12
This bill nullifies the recent interagency guidance issued by the Federal Reserve, OCC, and FDIC concerning climate-related financial risk management for large financial institutions. By voiding this specific guidance, the legislation prevents these agencies from enforcing those climate risk management principles. Furthermore, the bill prohibits the agencies from issuing any future guidance that is substantially similar to the canceled rules.
This legislation aims to completely nullify the “Principles for Climate-Related Financial Risk Management for Large Financial Institutions” guidance issued by the Federal Reserve, the Comptroller of the Currency (OCC), and the FDIC. In plain English, it cancels the rulebook that these three top financial regulators created to make sure the biggest banks are prepared for the financial fallout of climate change—things like severe weather events hitting collateral or shifts in energy policy affecting loan portfolios. Not only does this bill void that existing guidance, but it also explicitly blocks these agencies from enforcing it or issuing any future guidance that is “substantially similar” to the one being canceled (SEC. 1.).
When regulators issue guidance, it’s basically a set of expectations for how banks should manage a specific type of risk. The now-canceled climate risk guidance required large financial institutions to start thinking about climate change as a serious risk factor, integrating it into their governance, strategy, and risk management processes. For example, a bank lending heavily to coastal real estate or fossil fuel companies would have had to show how it was planning for rising sea levels or a rapid transition away from carbon. This bill means banks no longer have to do that work. It’s a win for the banks in the short term, as they save on the compliance costs and administrative burden of setting up these new risk frameworks.
This is where the rubber meets the road for everyday people. When financial institutions ignore or downplay systemic risks, those risks don't just disappear; they get absorbed by the system. If a major climate event—say, an unprecedented hurricane or a prolonged drought—causes widespread defaults across a bank’s loan portfolio, that instability can rattle the entire economy. The canceled guidance was designed to make sure banks internalized these costs and prepared for them, reducing the likelihood of a massive bailout or a financial crisis down the line. By removing this oversight, the bill effectively increases the public's exposure to climate-related financial instability. We, the taxpayers, become the default backstop if things go sideways because the big players weren't required to manage their own risk exposure.
A particularly strong provision in this bill is the prohibition against the Fed, OCC, and FDIC issuing any future guidance that is “substantially similar.” This isn't just about canceling one document; it’s about tying the hands of the financial watchdogs. Climate risk is a complex, evolving issue, and regulators need flexibility to adapt their rules as the science and the economy change. By using the vague term “substantially similar,” this bill creates a massive legal headache and uncertainty for the agencies, severely limiting their ability to proactively manage this specific area of systemic risk. It essentially tells the people tasked with protecting the financial system that they can't touch a whole category of growing risk, which is a significant reduction in their authority to maintain stability.