According to the Acting Chair of the OCC, "[Climate] risks can arise in many ways including contexts that relate to climate change, either because of physical conditions or climate-related transitions in business and other environments." He then goes on to say that the OCC is going to meetings and "cataloging" the risks.

Given the importance that the regulators are attaching to the issue of climate change, it is incumbent upon them to be more transparent as to the specific risks that…

FINRA's practice of treating every violation of a FINRA Rule as being also a Rule 2110 violation should lead to one of two conclusions: Rule 2010 should be deleted as duplicative; or Rule 2010 should be renamed "Violation of a FINRA Rule." That way, it will be clear that any firm that violates another FINRA Rule has also violated Rule 2010.

Acting Chair Lee's comments on disclosure suggest that she would support regulatory actions that not only raise first amendment concerns (by, for example, taking actions that might discourage advertising on disfavored shows), but also by potentially making the SEC a political actor by using those disclosure requirements in such a way as to determine which candidates for office may be deemed to be sufficiently ESG-favorable. (See prior .)

How will this approach translate into actual lending policies? Will the banking regulators discourage concentrated lending to coastal states, such as New York and California, on the theory that these geographies are subject to increased climate risk?