The Consumer Federation of America (CFA) submitted comments to the Federal Deposit Insurance Corporation (FDIC) on its draft principles designed to support the identification and management of climate-related financial risks by financial institutions with over $100 billion in assets. The comments stressed the need  for legislative and administrative action to address the existential threats of climate change and the resulting serious economic, environmental, and public health consequences.

The comments stress that climate change presents substantial risks to financial institutions, our financial system, and our economy, and many financial institutions will benefit from clear, holistic guidance on assessing those risks. Low- and moderate- income (LMI) consumers, communities of color, and other financially vulnerable Americans are especially susceptible to the effects of climate change and climate-related financial risks, and CFA urged the FDIC to pay particular attention to these consumers. CFA further recommended enacting mandatory requirements for considering climate-related financial risk, requiring financial institutions to divest from climate change exacerbating projects, and encouraging financial institutions to gather adequate expertise to address climate related financial risk.

CFA also joined onto coalition comments that focused on fair lending concerns.