"Climate-related risks are moving us toward a financial crisis. But regulators have not taken adequate steps to actually mitigate those risks."
The groups' letter was sent to key leaders at the U.S. Treasury Department, Federal Reserve, Federal Deposit Insurance Corporation (FDIC), National Economic Council, and relevant U.S. House and Senate committees.
After explaining how the SVB collapse is partly the result of poor management enabled by regulatory rollbacks under the Trump administration, the letter states that "this is only the latest example of a bank being wholly unprepared for a large and obvious financial risk."
The letter continues:
It is a stark reminder of the chaos that can unfold when a financial institution has high exposure to a risky industry, and of the fact that the leaders of major financial institutions are frequently far more concerned with their short-term gains than with robust risk management measures that ensure their safety and the safety and soundness of the financial system. As a reminder of the latter, senior managers at SVB paid themselves millions in bonuses hours before their bank failed and the federal government financially backstopped it. Here again, stronger rules—including the Dodd-Frank executive compensation rules that remain unfinished—could have incentivized greater bank attention to risks.
To prevent any potential for a cascade of bank runs after SVB's collapse, federal regulators have now effectively set a precedent of guaranteeing all bank deposits in all banking institutions nationwide, to be backstopped by the Federal Deposit Insurance Fund and then taxpayer dollars. Moreover, the Federal Reserve has begun lending at extraordinarily generous terms to any other banks with assets whose real value has been curbed by interest rate hikes—in effect, the Fed is offering a first-of-its-kind, get-out-of-bank-failure-free card to any firms that made the same foreseeable mistake as SVB. Regulators justified this extraordinary shift in the structures of American finance by relying on emergency rules in place to prevent systemic risk to the financial system. In effect, regulators argued that SVB's inability to mitigate one of the most obvious forms of financial risk—the potential for rising interest rates amid high inflation—constituted a grave risk to the whole financial system, and, thereby, the whole economy.
"If management at a wide swath of banks failed to properly address a well-understood risk, they cannot be trusted to independently address other complex emerging risks," the groups argued. "Regulators must intervene to protect the financial system from risks associated with climate change and the ongoing transition to a green economy."
The letter notes recent remarks from Treasury Secretary Janet Yellen about the economic and financial impact of the climate emergency as well as how, as it worsens, "banks of all sizes holding mortgage-backed bonds will see their assets drop in value" while "banks invested in the fossil fuel industry will eventually be saddled with stranded assets."
"Climate-related risks are moving us toward a financial crisis. But regulators have not taken adequate steps to actually mitigate those risks," the coalition warned, calling on U.S. policymakers to:
- Move with urgency and speed to implement proposed guidance for banks and financial institutions related to preparation for climate-related financial risks and to follow up with more detailed guidance;
- Rapidly move forward on rigorous exams for banking institutions, including for medium-sized banks, regardless of industry pressure for light-touch supervision of climate-related risks; and
- Please also see previous coalition letters recommending action on the Federal Reserve's and the Treasury Department's climate guidance.
"Banks cannot be trusted to independently evaluate and protect against the systemic risks of the climate crisis in real-time. They also cannot be trusted to avoid creating risks for other institutions and the financial system through their support for fossil assets and greenhouse gas emissions," the letter says. "This process requires regulators to set clear rules and ensure banks and financial institutions do not engage in unsafe behavior and do not create undue risks and costs for the financial system and the economy."
Signatories include Greenpeace USA, Lakota People's Law Project, Sierra Club, and Third Act—who came together earlier this month for a "Stop Dirty Banks" national day of action, the first elderly-led mass climate demonstration in U.S. history.
"Today is a major drive to take the cash out of carbon," declared Third Act's Bill McKibben. "We want JPMorgan Chase, Citi, Wells Fargo, and Bank of America to hear the voices of the older generation which has the money and structural power to face down their empty, weasel words on climate. We will not go to our graves quietly knowing that the financial institutions in our own communities continue to fund the climate crisis."