Climate-Related Financial Risk, 25028-25031 [2023-08715]
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Federal Register / Vol. 88, No. 79 / Tuesday, April 25, 2023 / Notices
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Jennifer Everling,
Acting Clerk of the Board.
[FR Doc. 2023–08650 Filed 4–24–23; 8:45 am]
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[FR Doc. 2023–08725 Filed 4–24–23; 8:45 am]
[Notice: (23–035)]
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Space Weather Council; Meeting
NATIONAL CREDIT UNION
ADMINISTRATION
National Aeronautics and
Space Administration.
ACTION: Notice of meeting.
AGENCY:
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In accordance with the
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Law 92–463, as amended, the National
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SUMMARY:
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[NCUA–2023–0045]
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Climate-Related Financial Risk
National Credit Union
Administration (NCUA).
ACTION: Request for information and
comment.
AGENCY:
The NCUA is seeking public
input on current and future climate and
natural disaster risks to federally
insured credit unions (FICUs), related
entities, their members, and the
National Credit Union Share Insurance
Fund (SIF). The NCUA also seeks input
of any interested parties on the
development of potential future
guidance, regulation, reporting
requirements, and/or supervisory
approaches for FICUs’ management of
climate-related financial risks.
SUMMARY:
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For consideration, comments
must be received on or before June 26,
2023.
ADDRESSES: You may submit comments
by any one of the following methods.
Please send comments by one method
only.
• Federal eRulemaking Portal:
https://www.regulations.gov. Follow the
instructions for submitting comments
for NCUA Docket [2023–XXXX].
• Fax: (703) 518–6319. Include
‘‘[Your name] Comments on ‘‘Request
for Information and Comment on
Climate-Related Financial Risk.’’
• Mail: Address to Melane ConyersAusbrooks, Secretary of the Board,
National Credit Union Administration,
1775 Duke Street, Alexandria, Virginia
22314–3428.
• Hand Delivery/Courier: Same as
mailing address.
Public Inspection: You may view all
public comments on the Federal
eRulemaking Portal at https://
www.regulations.gov as submitted,
except for those we cannot post for
technical reasons. NCUA will not edit or
remove any identifying or contact
information from the public comments
submitted. If you are unable to access
public comments on the internet, you
may contact the NCUA for alternative
access by calling (703) 518–6540 or
emailing OGCMail@ncua.gov.
FOR FURTHER INFORMATION CONTACT:
Policy and Analysis: Rachel Cononi,
Deputy Chief Economist (703) 303–2437
and Lisa Roberson, Deputy Director,
Office of Consumer Financial Protection
(703) 548–2466.
Legal: Marvin Shaw, Senior Staff
Attorney, (703) 518–6540; or by mail at
National Credit Union Administration,
1775 Duke Street, Alexandria, VA
22314.
SUPPLEMENTARY INFORMATION:
DATES:
NCUA Overview
The NCUA is an independent federal
agency that insures shares at FICUs 1
and charters and regulates federal credit
unions (FCUs). The NCUA is charged
with protecting the safety and
soundness of FICUs and, in turn, the SIF
through regulation and supervision. The
NCUA also works to protect credit
union members and consumers.
The NCUA’s mission is to ‘‘protect the
system of cooperative credit and its
member-owners through effective
chartering, supervision, regulation, and
insurance.’’ 2 Consistent with these
aims, the NCUA has statutory
1 Throughout this Request for Information, the
term FICUs and ‘‘credit union’’ is used
interchangeably.
2 NCUA Mission and Values web page.
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responsibility for a wide variety of
regulations that protect the credit union
system, members, and the SIF.
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Climate Risk and Its Relevance in the
Financial Sector
Climate change is accelerating and the
number—and cost—of climate-related
natural disasters is rising. The economic
effects of these events are clear. Each
year, natural disasters like hurricanes,
wildfires, droughts, and floods impose a
substantial financial toll on households
and businesses alike. The physical
effects of climate change along with
associated transition costs pose
significant risks to the U.S. economy
and the U.S. financial system.
In 2021, the United States
experienced 20 separate billion-dollar
weather and climate disaster events,
which caused an estimated $153 billion
in damage. Overall, 2021 was the third
most costly year on record for these
types of events and it was the seventh
consecutive year in which 10 or more
billion-dollar weather and climate
disaster events have occurred in the
United States. In 2022, there were an
estimated 15 billion-dollar disaster
events making it the eighth straight year
with 10 or more billion-dollar disaster
events. Together, these events caused an
estimated $165 billion in damage.3
Climate-related financial risks can be
grouped into two broad categories—
physical risk and transition risk.4
Physical risk refers to harm to people
and property caused by discrete,
climate-related events like hurricanes,
wildfires, and heatwaves, as well as
longer-term, chronic phenomena,
including changes in precipitation
patterns, sea level rise, and higher
average temperatures. Transition risk
refers to stress on institutions or sectors
caused by measures taken to move
towards a less carbon-intensive
economy. This includes responding to
public policy changes, adopting new
technologies, and adapting to shifts in
consumer and investor preferences,
which may lead to higher costs and
substantial shifts in asset values. If these
changes occur in a disorderly fashion,
the effect on individuals, businesses,
3 NOAA National Centers for Environmental
Information (NCEI) U.S. Billion-Dollar Weather and
Climate Disasters (2023). https://www.ncei.
noaa.gov/access/billions/, DOI: 10.25921/stkw–
7w73.
4 See, e.g., Basel Committee on Banking
Supervision, Climate-related Risk Drivers and Their
Transmission Channels (April 2021); Financial
Stability Board, The Implications of Climate Change
for Financial Stability (November 23, 2020); and
Market Risk Advisory Committee of the Commodity
Futures Trading Commission, Managing Climate
Risk in the U.S. Financial System (September 9,
2020).
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communities, and financial institutions
could be sudden and disruptive.
Economic and financial disruptions
and uncertainties arising from both the
physical and transition risks could
affect the credit union industry across
many dimensions. Climate-related
physical and transition risks tend to
manifest as traditional financial risks,
including credit risk, liquidity risk,
market risk, and operational risk. For
example, disruptions in economic
activity caused by climate-related
weather events like flooding or wildfires
may affect household income and the
ability to stay current on household
financial obligations. The property
damage associated with such events
could affect the value of homes and the
mortgages collateralized by residential
real estate. These events pose similar
risks to businesses and mortgages
collateralized by commercial real estate.
The policy and technological changes
needed to reduce the environmental
impact of human activities and move
towards a less carbon-intensive
economy may also have a wide range of
effects on the economy, businesses,
consumers, and thus credit unions. For
instance, the collateral value of motor
vehicles may be affected as consumer
preferences shift from gasoline-powered
vehicles to electric and hybrid vehicles.
Efforts to reduce greenhouse gas
emissions could lead to significant
adjustments in sectors of the economy
that are greenhouse gas-intensive,
including the energy, transportation,
manufacturing, and agricultural sectors.
Such adjustments may create new
business opportunities, such as the
creation of biodiesel products.
Households, businesses, and credit
unions with direct or indirect ties to
these sectors would also be affected.
Thus, any weaknesses in how a credit
union identifies, measure, monitors, and
mitigates physical and transition risks
could adversely affect a credit union’s
safety and soundness.
Credit unions need to consider
climate-related financial risks, and how
they could affect their membership and
institutional performance. For instance,
a credit union’s field of membership is
often tied to a particular industry or
community. To remain resilient and
retain the ability to offer their members
access to safe, fair, and affordable
financial services, credit unions may
need to consider adjustments to their
fields of membership as well as the
types of loan products they offer.
Low-income and minority
communities are particularly vulnerable
to climate-related financial risk.
Climate-related disasters can cause
property damage and can also lead to
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job losses and undermine economic
output, reducing already limited
household income and wealth and
diminishing access to capital.
Additionally, absent any mitigating
actions, changes in government policy,
programs, or guidelines to transition to
a less carbon-intensive economy may
unintentionally increase the cost of
homeownership in vulnerable
communities. Financially vulnerable
households and communities are the
least able to absorb the costs associated
with climate-related disasters, so these
consumers may have more difficulty
adapting to changes in government
policies and the natural environment.
Thus, climate-related financial risks
may be amplified for FICUs serving
these communities.
Climate change presents several
complex conceptual and practical
challenges not only for credit unions,
but also for the NCUA. Just as credit
unions must continue to adapt to
account for climate-related financial
risks, the NCUA will need to evolve its
understanding of the impact on credit
unions, credit union members, the
credit union system, and the SIF. The
information collected from the
responses to the questions below will
assist the agency in developing tools to
identify and assess current and future
risks to FICUs and the SIF. Stakeholder
feedback will also inform the agency’s
future decisions on the best way to
address these risks. And, the responses
of interested parties will allow the
agency to better understand how credit
union members may be affected by these
risks.
Request for Comment
The Board seeks comments on the
current and future climate and natural
disaster risks faced by FICUs. The
NCUA is broadly interested in
understanding stakeholders’ views and
experiences in this area. Commenters
are also encouraged to discuss any and
all relevant issues they believe the
Board should consider with respect to
the financial risks associated with
climate change. This includes, but is not
limited to, risks posed to, or stemming
from, field of membership, lending,
investments, other assets, deposits,
underwriting standards, insurance
coverage, liquidity, and capital.
The Board’s request for information
should not imply any intention to
modify any existing requirements
applicable to FICUs and does not grant
FICUs any new authorities or limit any
existing authorities. The request for
information does not speak to the
permissibility or impermissibility of any
specific activity. Additionally, any
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information provided by credit unions
as part of this RFI will not be used in
the examination and supervision of
individual credit unions. Any new
requirements for credit unions
associated with climate-related financial
risk would require changes to
examination and supervision
procedures and Board action and
approval before implementing.
Moreover, as a prudential financial
regulator, the NCUA does not have
expertise in climate science. As set forth
in the questions below, the NCUA is
seeking input that would strengthen its
ability to identify and assess credit
unions’ current and future climate and
natural disaster risk. The NCUA is also
seeking input on opportunities to
enhance the agency’s supervision and
regulation of each regulated entity’s
management of such risks.
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Physical Risk
1. Climate-related events, including
floods, sea level rise, hurricanes, winds,
wildfires, and drought, may affect credit
union operations (for example, office
buildings, supply chain); commercial
and residential real estate; agricultural,
commercial, and industrial lending; and
small business lending. What climaterelated physical risks, if any, are
affecting the industry? How might
physical risks and the impact of these
risks on credit unions and their
members change over time?
2. What risk management strategies
could institutions implement to prepare
for or minimize the effects of physical
risk? Is there anything regulators should
do to help institutions address physical
risks?
3. What impact are physical risks
expected to have on credit union
members, particularly financially
vulnerable populations, including
lower-income communities,
communities of color, Native American,
and other under-resourced
communities? What steps could credit
unions take to mitigate physical risks to
ensure continued lending to these
populations?
Transition Risk
4. Transition risks from climate
change can come from government
policy changes, including changes to
zoning laws; other federal, state and
local laws and regulations;
technological changes; and consumer
and market demand. What climaterelated transition risks are affecting or
could affect credit unions in the various
areas of business activities, including,
but not limited to, operations, real estate
lending, commercial lending, and small
business lending?
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5. What risk management strategies
could credit unions implement to
prepare for or minimize the effects of
transition risk? Is there anything
regulators can do to help credit unions
address transition risk?
6. What effects are transition risks
expected to have on credit union
members, particularly financially
vulnerable populations, including
lower-income communities,
communities of color, Native American,
and other under-resourced
communities? What steps could credit
unions take to mitigate transition risks
to ensure continued lending to these
populations?
Operations
7. What adjustments should credit
unions make to their operations
(including relationships with supply
chain and third parties, new product
and service offerings, among others) in
response to climate-related financial
risks?
Governance
8. What role should a credit union’s
board of directors have in the oversight
and analysis of financial risks due to
climate change?
9. How can credit unions incorporate
climate-related financial risks into their
overall risk management and
governance framework?
10. Do credit unions have board
members, committees, or senior
management functions that are
responsible for climate-related financial
risks? If yes, please provide examples.
11. What are the top barriers/
challenges for credit unions in
designating board members,
committees, and/or senior management
functions to be responsible for climaterelated financial risks?
12. Do credit union boards and senior
management have, or are they aware of
and have an understanding of, the tools
and resources necessary to evaluate and
address climate-related financial risk?
What, if any, are other barriers for
addressing climate-related financial
risks?
Business Strategies
13. How should credit unions
consider climate-related financial risks
in developing business strategies? How
do these risks impact product and
service offerings?
14. In what ways may credit unions
need to incorporate climate-related
financial risks into business strategies
and product and service offerings?
15. If you are a credit union, has your
board and management assessed the
impact of climate change on the credit
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union’s products and services? If yes,
please briefly describe how you have
assessed the impact of climate change
on your credit union’s products and
services.
16. What barriers or challenges do
credit unions face in considering
climate change in business strategies
and product offerings? Does your board
or senior management believe climate
change is a material risk to the credit
union’s business?
17. Do credit unions have sufficient
expertise or are they aware of and have
an understanding of the tools and
resources necessary to address the
financial risks and opportunities
associated with climate change and
their impact on credit union
performance? Do you think considering
climate-related financial risks may put
credit unions at a competitive
disadvantage?
18. Do credit unions take steps to
assess, reduce, or mitigate its climate
impact? If you are a credit union
answering this question, please describe
what your credit union has done. If your
credit union has not taken such steps,
do you plan to do so and what is your
time frame? If your credit union does
not plan to take such steps, please
briefly describe the reason(s) for not
doing so. What barriers exist that
prevent your credit union from taking
such steps?
Risk Management
19. What methods can credit unions
use to identify, measure, monitor,
manage, and report on their exposure to
climate-related financial risks? Please
provide a brief description of the risk
management process credit unions
should take. If you are a credit union,
please provide a link to your climate
policy. If you are a credit union and do
not have a risk management process, do
you plan to develop a process? What is
the anticipated time frame for
developing such a process? If you do not
plan to develop such a process, please
explain your rationale for this decision.
20. Credit unions typically evaluate
credit risk, interest rate risk, liquidity
risk, transaction risk, strategic risk,
reputation risk, and compliance risk.
How do climate-related financial risks
impact these traditional risk areas? To
what extent should a credit union
consider climate change in analyzing
these and other existing risk factors?
21. What risk mitigation strategies can
credit unions use to transfer some or all
of the financial risks associated with
climate change? Are these mitigation
tools cost effective?
22. When credit unions consider
climate change in analyzing existing
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risk factors, should they include the risk
of adverse effects of climate change on
financially vulnerable populations,
including lower-income communities,
communities of color, Native American,
and other disadvantaged or underresourced communities? If you are a
credit union, are you considering
climate-related financial risks specific to
financially-vulnerable populations?
23. If your credit union does not
currently consider climate change in
analyzing its existing risk factors, do
you anticipate doing so? How long will
it take to do so? If you do not plan to
do so, please briefly describe your
reasons or barriers.
24. What are the top barriers for credit
unions to consider (or that credit unions
have encountered) in creating a risk
management process for climate-related
financial risks and/or including climate
change in its analysis of existing risk
factors? Does your board or senior
management not consider climate
change as posing a material risk to your
credit union’s business?
25. What types of data or products are
necessary to assist credit unions in
evaluating exposure to climate-related
financial risks?
26. Do credit unions have sufficient
understanding of the climate-related
risk management process? Do credit
unions have sufficient understanding of
how climate change affects existing risk
factors? Please specify any other barriers
credit unions face in assessing climaterelated risk.
27. If your credit union is involved in
the mortgage business, what tools does
your credit union use to manage flood
risk? What additional tools would be
helpful to your credit union?
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Reporting and Targets
28. What internal reporting systems
are you aware of that would assist credit
unions in evaluating climate-related
financial risks? Please provide a brief
description of these internal reporting
systems. If provided by third parties,
what are the costs of these reporting
systems?
Climate-Related Opportunities
29. Climate change and efforts to
address climate change may also present
new opportunities for credit unions.
What products and services do credit
unions offer in response to physical and
transition risk (for example renewable
energy loan products and services, such
as loans for solar power generation or
biodiesel development)? What are the
top drivers for offering these products
and services?
30. Are you aware of credit unions or
does your credit union finance clean
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energy projects such as residential or
commercial energy efficiency upgrades
and solar installations? Is this financing
of clean energy products just one of
many services provided by the credit
union or part of an overall business
strategy? If you provide clean energy
products, please provide the estimated
size of your clean energy portfolio and
what percent it represents of your
overall lending. If no, please briefly
describe any challenges for credit
unions to offering this type of lending.
Please also discuss the barriers to
underwriting clean energy loans within
under-resourced communities.
31. Each type of lending involves
various areas of expertise such as
underwriting, guidance for loan loss
reserves, and/or technical assistance
such as how to lend or acquire interest
in climate-related and environmentally
conscious loan products. What kind of
support do credit unions need to
expand products and services? Please
describe any barriers to entry as well as
the types of information or resources
needed to facilitate a credit union’s
ability to offer climate-related and
environmentally conscious loan
products.
32. Are there any climate-related
opportunities, in addition to renewable
energy, that credit unions should
consider?
33. What regulatory changes would be
necessary to encourage credit unions to
develop products and services designed
to capitalize on opportunities presented
by the transition to clean energy and a
less carbon intensive economy?
Suggestions for NCUA
34. The NCUA understands that
managing the financial risks of climate
change is an evolving field and new to
some credit unions. The NCUA is
exploring several options to support
credit unions in these efforts, including
sharing industry best practices,
providing guidance on how to manage
the potential financial risks from
climate change, convening workshops
with the industry to discuss climaterelated financial risk topics, and hosting
educational seminars on how climate
change may impact the financial system
and individual credit unions. What
efforts would be the most beneficial to
credit unions?
35. Should the NCUA modify its
examination procedures and
supervisory posture in relation to
climate-related financial risk? This
would be including, but not limited to,
Flood Disaster Protection Act, Disaster
Preparedness reviews, CAMELS ratings,
and assessments of the level and
direction of the various areas of risk.
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Data Gathering
36. How can the NCUA support
efforts to develop standards of
classification and data reporting on
climate-related financial risks?
37. What data could the NCUA collect
to improve credit unions’ understanding
of climate-related financial risks and
support credit union efforts to manage
these risks?
Questions for NCUA
38. Please provide any questions or
comments not covered in this request
for information that you would like the
NCUA to address regarding to climaterelated financial risk.
Authority: 12 U.S.C. 1756 and 1784.
By the NCUA Board on April 20, 2023.
Melane Conyers-Ausbrooks,
Secretary of the Board.
[FR Doc. 2023–08715 Filed 4–24–23; 8:45 am]
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[FR Doc. 2023–08674 Filed 4–24–23; 8:45 am]
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Agencies
[Federal Register Volume 88, Number 79 (Tuesday, April 25, 2023)]
[Notices]
[Pages 25028-25031]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2023-08715]
=======================================================================
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NATIONAL CREDIT UNION ADMINISTRATION
[NCUA-2023-0045]
RIN 3133-AF52
Climate-Related Financial Risk
AGENCY: National Credit Union Administration (NCUA).
ACTION: Request for information and comment.
-----------------------------------------------------------------------
SUMMARY: The NCUA is seeking public input on current and future climate
and natural disaster risks to federally insured credit unions (FICUs),
related entities, their members, and the National Credit Union Share
Insurance Fund (SIF). The NCUA also seeks input of any interested
parties on the development of potential future guidance, regulation,
reporting requirements, and/or supervisory approaches for FICUs'
management of climate-related financial risks.
DATES: For consideration, comments must be received on or before June
26, 2023.
ADDRESSES: You may submit comments by any one of the following methods.
Please send comments by one method only.
Federal eRulemaking Portal: https://www.regulations.gov.
Follow the instructions for submitting comments for NCUA Docket [2023-
XXXX].
Fax: (703) 518-6319. Include ``[Your name] Comments on
``Request for Information and Comment on Climate-Related Financial
Risk.''
Mail: Address to Melane Conyers-Ausbrooks, Secretary of
the Board, National Credit Union Administration, 1775 Duke Street,
Alexandria, Virginia 22314-3428.
Hand Delivery/Courier: Same as mailing address.
Public Inspection: You may view all public comments on the Federal
eRulemaking Portal at https://www.regulations.gov as submitted, except
for those we cannot post for technical reasons. NCUA will not edit or
remove any identifying or contact information from the public comments
submitted. If you are unable to access public comments on the internet,
you may contact the NCUA for alternative access by calling (703) 518-
6540 or emailing [email protected].
FOR FURTHER INFORMATION CONTACT:
Policy and Analysis: Rachel Cononi, Deputy Chief Economist (703)
303-2437 and Lisa Roberson, Deputy Director, Office of Consumer
Financial Protection (703) 548-2466.
Legal: Marvin Shaw, Senior Staff Attorney, (703) 518-6540; or by
mail at National Credit Union Administration, 1775 Duke Street,
Alexandria, VA 22314.
SUPPLEMENTARY INFORMATION:
NCUA Overview
The NCUA is an independent federal agency that insures shares at
FICUs \1\ and charters and regulates federal credit unions (FCUs). The
NCUA is charged with protecting the safety and soundness of FICUs and,
in turn, the SIF through regulation and supervision. The NCUA also
works to protect credit union members and consumers.
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\1\ Throughout this Request for Information, the term FICUs and
``credit union'' is used interchangeably.
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The NCUA's mission is to ``protect the system of cooperative credit
and its member-owners through effective chartering, supervision,
regulation, and insurance.'' \2\ Consistent with these aims, the NCUA
has statutory
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responsibility for a wide variety of regulations that protect the
credit union system, members, and the SIF.
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\2\ NCUA Mission and Values web page.
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Climate Risk and Its Relevance in the Financial Sector
Climate change is accelerating and the number--and cost--of
climate-related natural disasters is rising. The economic effects of
these events are clear. Each year, natural disasters like hurricanes,
wildfires, droughts, and floods impose a substantial financial toll on
households and businesses alike. The physical effects of climate change
along with associated transition costs pose significant risks to the
U.S. economy and the U.S. financial system.
In 2021, the United States experienced 20 separate billion-dollar
weather and climate disaster events, which caused an estimated $153
billion in damage. Overall, 2021 was the third most costly year on
record for these types of events and it was the seventh consecutive
year in which 10 or more billion-dollar weather and climate disaster
events have occurred in the United States. In 2022, there were an
estimated 15 billion-dollar disaster events making it the eighth
straight year with 10 or more billion-dollar disaster events. Together,
these events caused an estimated $165 billion in damage.\3\
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\3\ NOAA National Centers for Environmental Information (NCEI)
U.S. Billion-Dollar Weather and Climate Disasters (2023). https://www.ncei.noaa.gov/access/billions/, DOI: 10.25921/stkw-7w73.
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Climate-related financial risks can be grouped into two broad
categories--physical risk and transition risk.\4\ Physical risk refers
to harm to people and property caused by discrete, climate-related
events like hurricanes, wildfires, and heatwaves, as well as longer-
term, chronic phenomena, including changes in precipitation patterns,
sea level rise, and higher average temperatures. Transition risk refers
to stress on institutions or sectors caused by measures taken to move
towards a less carbon-intensive economy. This includes responding to
public policy changes, adopting new technologies, and adapting to
shifts in consumer and investor preferences, which may lead to higher
costs and substantial shifts in asset values. If these changes occur in
a disorderly fashion, the effect on individuals, businesses,
communities, and financial institutions could be sudden and disruptive.
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\4\ See, e.g., Basel Committee on Banking Supervision, Climate-
related Risk Drivers and Their Transmission Channels (April 2021);
Financial Stability Board, The Implications of Climate Change for
Financial Stability (November 23, 2020); and Market Risk Advisory
Committee of the Commodity Futures Trading Commission, Managing
Climate Risk in the U.S. Financial System (September 9, 2020).
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Economic and financial disruptions and uncertainties arising from
both the physical and transition risks could affect the credit union
industry across many dimensions. Climate-related physical and
transition risks tend to manifest as traditional financial risks,
including credit risk, liquidity risk, market risk, and operational
risk. For example, disruptions in economic activity caused by climate-
related weather events like flooding or wildfires may affect household
income and the ability to stay current on household financial
obligations. The property damage associated with such events could
affect the value of homes and the mortgages collateralized by
residential real estate. These events pose similar risks to businesses
and mortgages collateralized by commercial real estate.
The policy and technological changes needed to reduce the
environmental impact of human activities and move towards a less
carbon-intensive economy may also have a wide range of effects on the
economy, businesses, consumers, and thus credit unions. For instance,
the collateral value of motor vehicles may be affected as consumer
preferences shift from gasoline-powered vehicles to electric and hybrid
vehicles. Efforts to reduce greenhouse gas emissions could lead to
significant adjustments in sectors of the economy that are greenhouse
gas-intensive, including the energy, transportation, manufacturing, and
agricultural sectors. Such adjustments may create new business
opportunities, such as the creation of biodiesel products. Households,
businesses, and credit unions with direct or indirect ties to these
sectors would also be affected. Thus, any weaknesses in how a credit
union identifies, measure, monitors, and mitigates physical and
transition risks could adversely affect a credit union's safety and
soundness.
Credit unions need to consider climate-related financial risks, and
how they could affect their membership and institutional performance.
For instance, a credit union's field of membership is often tied to a
particular industry or community. To remain resilient and retain the
ability to offer their members access to safe, fair, and affordable
financial services, credit unions may need to consider adjustments to
their fields of membership as well as the types of loan products they
offer.
Low-income and minority communities are particularly vulnerable to
climate-related financial risk. Climate-related disasters can cause
property damage and can also lead to job losses and undermine economic
output, reducing already limited household income and wealth and
diminishing access to capital. Additionally, absent any mitigating
actions, changes in government policy, programs, or guidelines to
transition to a less carbon-intensive economy may unintentionally
increase the cost of homeownership in vulnerable communities.
Financially vulnerable households and communities are the least able to
absorb the costs associated with climate-related disasters, so these
consumers may have more difficulty adapting to changes in government
policies and the natural environment. Thus, climate-related financial
risks may be amplified for FICUs serving these communities.
Climate change presents several complex conceptual and practical
challenges not only for credit unions, but also for the NCUA. Just as
credit unions must continue to adapt to account for climate-related
financial risks, the NCUA will need to evolve its understanding of the
impact on credit unions, credit union members, the credit union system,
and the SIF. The information collected from the responses to the
questions below will assist the agency in developing tools to identify
and assess current and future risks to FICUs and the SIF. Stakeholder
feedback will also inform the agency's future decisions on the best way
to address these risks. And, the responses of interested parties will
allow the agency to better understand how credit union members may be
affected by these risks.
Request for Comment
The Board seeks comments on the current and future climate and
natural disaster risks faced by FICUs. The NCUA is broadly interested
in understanding stakeholders' views and experiences in this area.
Commenters are also encouraged to discuss any and all relevant issues
they believe the Board should consider with respect to the financial
risks associated with climate change. This includes, but is not limited
to, risks posed to, or stemming from, field of membership, lending,
investments, other assets, deposits, underwriting standards, insurance
coverage, liquidity, and capital.
The Board's request for information should not imply any intention
to modify any existing requirements applicable to FICUs and does not
grant FICUs any new authorities or limit any existing authorities. The
request for information does not speak to the permissibility or
impermissibility of any specific activity. Additionally, any
[[Page 25030]]
information provided by credit unions as part of this RFI will not be
used in the examination and supervision of individual credit unions.
Any new requirements for credit unions associated with climate-related
financial risk would require changes to examination and supervision
procedures and Board action and approval before implementing.
Moreover, as a prudential financial regulator, the NCUA does not
have expertise in climate science. As set forth in the questions below,
the NCUA is seeking input that would strengthen its ability to identify
and assess credit unions' current and future climate and natural
disaster risk. The NCUA is also seeking input on opportunities to
enhance the agency's supervision and regulation of each regulated
entity's management of such risks.
Physical Risk
1. Climate-related events, including floods, sea level rise,
hurricanes, winds, wildfires, and drought, may affect credit union
operations (for example, office buildings, supply chain); commercial
and residential real estate; agricultural, commercial, and industrial
lending; and small business lending. What climate-related physical
risks, if any, are affecting the industry? How might physical risks and
the impact of these risks on credit unions and their members change
over time?
2. What risk management strategies could institutions implement to
prepare for or minimize the effects of physical risk? Is there anything
regulators should do to help institutions address physical risks?
3. What impact are physical risks expected to have on credit union
members, particularly financially vulnerable populations, including
lower-income communities, communities of color, Native American, and
other under-resourced communities? What steps could credit unions take
to mitigate physical risks to ensure continued lending to these
populations?
Transition Risk
4. Transition risks from climate change can come from government
policy changes, including changes to zoning laws; other federal, state
and local laws and regulations; technological changes; and consumer and
market demand. What climate-related transition risks are affecting or
could affect credit unions in the various areas of business activities,
including, but not limited to, operations, real estate lending,
commercial lending, and small business lending?
5. What risk management strategies could credit unions implement to
prepare for or minimize the effects of transition risk? Is there
anything regulators can do to help credit unions address transition
risk?
6. What effects are transition risks expected to have on credit
union members, particularly financially vulnerable populations,
including lower-income communities, communities of color, Native
American, and other under-resourced communities? What steps could
credit unions take to mitigate transition risks to ensure continued
lending to these populations?
Operations
7. What adjustments should credit unions make to their operations
(including relationships with supply chain and third parties, new
product and service offerings, among others) in response to climate-
related financial risks?
Governance
8. What role should a credit union's board of directors have in the
oversight and analysis of financial risks due to climate change?
9. How can credit unions incorporate climate-related financial
risks into their overall risk management and governance framework?
10. Do credit unions have board members, committees, or senior
management functions that are responsible for climate-related financial
risks? If yes, please provide examples.
11. What are the top barriers/challenges for credit unions in
designating board members, committees, and/or senior management
functions to be responsible for climate-related financial risks?
12. Do credit union boards and senior management have, or are they
aware of and have an understanding of, the tools and resources
necessary to evaluate and address climate-related financial risk? What,
if any, are other barriers for addressing climate-related financial
risks?
Business Strategies
13. How should credit unions consider climate-related financial
risks in developing business strategies? How do these risks impact
product and service offerings?
14. In what ways may credit unions need to incorporate climate-
related financial risks into business strategies and product and
service offerings?
15. If you are a credit union, has your board and management
assessed the impact of climate change on the credit union's products
and services? If yes, please briefly describe how you have assessed the
impact of climate change on your credit union's products and services.
16. What barriers or challenges do credit unions face in
considering climate change in business strategies and product
offerings? Does your board or senior management believe climate change
is a material risk to the credit union's business?
17. Do credit unions have sufficient expertise or are they aware of
and have an understanding of the tools and resources necessary to
address the financial risks and opportunities associated with climate
change and their impact on credit union performance? Do you think
considering climate-related financial risks may put credit unions at a
competitive disadvantage?
18. Do credit unions take steps to assess, reduce, or mitigate its
climate impact? If you are a credit union answering this question,
please describe what your credit union has done. If your credit union
has not taken such steps, do you plan to do so and what is your time
frame? If your credit union does not plan to take such steps, please
briefly describe the reason(s) for not doing so. What barriers exist
that prevent your credit union from taking such steps?
Risk Management
19. What methods can credit unions use to identify, measure,
monitor, manage, and report on their exposure to climate-related
financial risks? Please provide a brief description of the risk
management process credit unions should take. If you are a credit
union, please provide a link to your climate policy. If you are a
credit union and do not have a risk management process, do you plan to
develop a process? What is the anticipated time frame for developing
such a process? If you do not plan to develop such a process, please
explain your rationale for this decision.
20. Credit unions typically evaluate credit risk, interest rate
risk, liquidity risk, transaction risk, strategic risk, reputation
risk, and compliance risk. How do climate-related financial risks
impact these traditional risk areas? To what extent should a credit
union consider climate change in analyzing these and other existing
risk factors?
21. What risk mitigation strategies can credit unions use to
transfer some or all of the financial risks associated with climate
change? Are these mitigation tools cost effective?
22. When credit unions consider climate change in analyzing
existing
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risk factors, should they include the risk of adverse effects of
climate change on financially vulnerable populations, including lower-
income communities, communities of color, Native American, and other
disadvantaged or under-resourced communities? If you are a credit
union, are you considering climate-related financial risks specific to
financially-vulnerable populations?
23. If your credit union does not currently consider climate change
in analyzing its existing risk factors, do you anticipate doing so? How
long will it take to do so? If you do not plan to do so, please briefly
describe your reasons or barriers.
24. What are the top barriers for credit unions to consider (or
that credit unions have encountered) in creating a risk management
process for climate-related financial risks and/or including climate
change in its analysis of existing risk factors? Does your board or
senior management not consider climate change as posing a material risk
to your credit union's business?
25. What types of data or products are necessary to assist credit
unions in evaluating exposure to climate-related financial risks?
26. Do credit unions have sufficient understanding of the climate-
related risk management process? Do credit unions have sufficient
understanding of how climate change affects existing risk factors?
Please specify any other barriers credit unions face in assessing
climate-related risk.
27. If your credit union is involved in the mortgage business, what
tools does your credit union use to manage flood risk? What additional
tools would be helpful to your credit union?
Reporting and Targets
28. What internal reporting systems are you aware of that would
assist credit unions in evaluating climate-related financial risks?
Please provide a brief description of these internal reporting systems.
If provided by third parties, what are the costs of these reporting
systems?
Climate-Related Opportunities
29. Climate change and efforts to address climate change may also
present new opportunities for credit unions. What products and services
do credit unions offer in response to physical and transition risk (for
example renewable energy loan products and services, such as loans for
solar power generation or biodiesel development)? What are the top
drivers for offering these products and services?
30. Are you aware of credit unions or does your credit union
finance clean energy projects such as residential or commercial energy
efficiency upgrades and solar installations? Is this financing of clean
energy products just one of many services provided by the credit union
or part of an overall business strategy? If you provide clean energy
products, please provide the estimated size of your clean energy
portfolio and what percent it represents of your overall lending. If
no, please briefly describe any challenges for credit unions to
offering this type of lending. Please also discuss the barriers to
underwriting clean energy loans within under-resourced communities.
31. Each type of lending involves various areas of expertise such
as underwriting, guidance for loan loss reserves, and/or technical
assistance such as how to lend or acquire interest in climate-related
and environmentally conscious loan products. What kind of support do
credit unions need to expand products and services? Please describe any
barriers to entry as well as the types of information or resources
needed to facilitate a credit union's ability to offer climate-related
and environmentally conscious loan products.
32. Are there any climate-related opportunities, in addition to
renewable energy, that credit unions should consider?
33. What regulatory changes would be necessary to encourage credit
unions to develop products and services designed to capitalize on
opportunities presented by the transition to clean energy and a less
carbon intensive economy?
Suggestions for NCUA
34. The NCUA understands that managing the financial risks of
climate change is an evolving field and new to some credit unions. The
NCUA is exploring several options to support credit unions in these
efforts, including sharing industry best practices, providing guidance
on how to manage the potential financial risks from climate change,
convening workshops with the industry to discuss climate-related
financial risk topics, and hosting educational seminars on how climate
change may impact the financial system and individual credit unions.
What efforts would be the most beneficial to credit unions?
35. Should the NCUA modify its examination procedures and
supervisory posture in relation to climate-related financial risk? This
would be including, but not limited to, Flood Disaster Protection Act,
Disaster Preparedness reviews, CAMELS ratings, and assessments of the
level and direction of the various areas of risk.
Data Gathering
36. How can the NCUA support efforts to develop standards of
classification and data reporting on climate-related financial risks?
37. What data could the NCUA collect to improve credit unions'
understanding of climate-related financial risks and support credit
union efforts to manage these risks?
Questions for NCUA
38. Please provide any questions or comments not covered in this
request for information that you would like the NCUA to address
regarding to climate-related financial risk.
Authority: 12 U.S.C. 1756 and 1784.
By the NCUA Board on April 20, 2023.
Melane Conyers-Ausbrooks,
Secretary of the Board.
[FR Doc. 2023-08715 Filed 4-24-23; 8:45 am]
BILLING CODE 7535-01-P