OCC Renews Climate Risk Management Survey for Large Banks

On January 18, 2022, the Office of the Comptroller of the Currency (“OCC”) announced the renewal of the survey it created addressing climate risk management practices at larger OCC-regulated banks. 

The survey is the same as originally distributed—containing 17, predominantly multiple-choice, questions with follow-up commentary and supplementary documents requested. The majority of these questions are purportedly intended to determine whether the receiving institutions have developed or are planning to develop policies and practices to address climate risk management. Additionally, other questions in the survey imply large banks should consider establishing and adopting voluntary disclosure framework for climate-related information and that banks should eventually consider climate risks in making financial decisions impacting consumers. 

The survey was originally distributed to banks to be completed on a voluntary basis, unless contacted by the OCC, and had a due date of December 6, 2021. Under the renewal timeline, written comments must be submitted by March 21, 2022 to the following:

• Mail:

Chief Counsel's Office

Attention: Comment Processing,

Office of the Comptroller of the Currency,

400 7th Street SW, Suite 3E-218

Washington, DC 20219

• Hand Delivery/Courier:

400 7th Street SW, Suite 3E-218

Washington, DC 20219

Financial institutions of all sizes should continue to monitor this public comment process to remain informed on the current legislative scheme for financial institutions to best prepare their institution.