Better Markets fights throughout the economic and financial rulemaking and policymaking processes for an economy that works for all Americans, and a financial system that supports the productive economy, jobs, small businesses, community banks, and Main Street families, workers, and investors.  That’s a financial system that minimizes socially useless wealth extraction and generates broad based wealth creation, enabling rising living standards as well as economic, social, and racial justice.

In addition to the existential crisis it poses, climate change looms as an inevitable trigger of profound instability and eventual crisis in our financial system and our entire economy if it is not aggressively attacked on all fronts.  Better Markets takes a holistic approach and is active across all the financial regulatory agencies plus the White House, Congress and the media (as summarized here), while taking a comprehensive approach as mapped out in our Arc of Advocacy.

Quick examples of some of our activities at the various regulatory agencies include:

• At the SEC, we have been deeply involved in all three climate related rulemakings: the first was its proposal to require investment companies, advisers, and other entities to disclose to investorsadditional information regarding their ESG investment strategies (pending); the second was to modernize the requirements regarding investment company names (read our statement here on the finalization of the rule); and in the third we strongly supported the SEC’s comprehensive Climate-Risk Disclosure proposal (read our statement here on the finalization of the rule).
• At the banking agencies, we have been pushing the banking regulators on climate since long before the Federal Reserve announced it was “formally” although very belatedly joined the Network for Greening the Financial System. More recently, at the Fed, we commentedon its draft Principles for Climate-Related Financial Risk Management for Large Financial Institutions; at the FDIC, we pushed them to take more consequential steps toward managing climate related financial risks; at the OCC, we encouraged them to proposing to incorporate climate related risks into bank supervision and assessment and  applauded them when they did.
• At the Treasury Department, where the Treasury Secretary is the Chair of the FSOC, we urged FSOC to act in its role as a “convener and coordinator” to address climate risks in our 2021 climate report, and highlighted the FSOC’s limited and insufficient attention to climate in our groundbreaking 2023 report “The Unseen Banking Crisis Concealed Behind the Climate Crisis;” we also joined a coalition encouraging Secretary Yellen to name a senior experienced climate official, joined with others in letters to the FIO for an insurance coverage data call and for more transparency around data collection.
• At the CFTC, we’ve advocated for action in the derivatives and commodities spaces on climate related risks, and in a comment letter earlier this year, our team supported a proposal to address the urgent climate crisis by enhancing transparency and integrity in the carbon credit markets.
• At the CFPB, we filed a comment letter on a proposed rule strengthening underwriting standards and consumer protections to stop predatory conduct in connection with the financing people get for clean-energy improvements on their homes.

While there are numerous other activities that accompany our climate-related work, here is a comprehensive list of the climate-related documents we have created/distributed:

• We released a Fact Sheet detailing the impact of climate events on banking and insurance and called for five things that must change related to managing climate-related financial risk. (11/19/24)
• Better Markets’ Legal Director Steve Hall took part in a Federal Society webinar – Climate Disclosure Litigation: Examining Legal Battles Against California and the SEC.
• Our team criticized FSOC for once again not taking more concrete action to combat climate change. (9/20/24)
• Our fact sheet outlined historic steps the CFTC was taking on reforming Voluntary Carbon credits and pushed the agency to do even more. (10/10/24)
• In an amicus brief our team argued that the SEC has crystal-clear statutory authority to require company climate risk disclosures that protect helps investors and serve the public interest. (8/15/24)
• In a comment letter our team argued that the Basel Committee is right to strengthen analysis of climate-related financial risks at banks, and the US should follow suit. (7/15/24)
• Our Earth Day Fact Sheet stressed the urgency to address the many financial risks caused by climate risks. (4/22/24)
• As the House Financial Services Committee traveled to Tennessee bash SEC climate disclosure rules, our team flagged the growing risk of climate change for Tennessee families. (3/15/24)
• We submitted a comment letter urging the Basel Committee on Banking Supervision to further strengthen and adopt the proposed requirements on disclosure of Climate-Related Financial Risks. (3/14/24)
• Our statement on the SEC’s climate rule criticized the agency for not doing enough to protect investors, markets and financial stability. (3/6/24)
• We called on the SEC to swiftly approve important propose rules on climate change and ESG. (2/21/24)
• In a comment letter to the CFTC, our team supported a proposal to address the urgent climate crisis by enhancing transparency and integrity in the carbon credit markets. (2/16/24)
• In a new report our team evaluated the growing risk of climate change to both the insurance industry and the banking sector and its potential impact on our entire financial system. (8/23/23)
• Better Markets Legal Director and Securities Specialist Stephen Hall wrote an article in the Environmental Law Reporter on regulation and ESG funds. (8/1/23)
• Our team examined the need for banking regulators to include climate related financial risks in their risk analysis- Fact Sheet: Politics Aside, Banking Regulators’ Risk Analysis Must Include the Many Well-Known Climate-Related Financial Risks (7/17/23)
• Stephen Hall, our legal director and securities specialist, spoke at the CFA Institute Climate Risk and Returns Conference this April. Steve’s panel explored how public policymakers, corporations, the investment community, and individual citizens all must work together to address climate change. Steve put together a blog based on his presentation at the panel. (5/3/2023)
• Better Markets highlighted the widespread, mainstream, consensus from Washington to Wall Street and beyond that climate change poses serious and dangerous risks to the financial system and the economy-  Fact Sheet: Financial Risks Related to Climate Change Must Be Addressed—Republicans, Democrats, Wall Street Banks, Finance Leaders Agree (2/9/2022)
• We outlined the impact of climate change on the banking system and what regulators should prioritize- Report: Climate Change & the Banking System (11/2/2021)
• We urged supervisory assessment framework that must also include assessments of climate change-related issues- Report: The Agenda for the Fed’s Next Vice Chair for Supervision (Climate Related Arguments- 10/7/2021)
• Our team emphasized the importance of the Fed’s role in climate change- Report: Should Federal Reserve Chairman Jay Powell Be Reappointed? (Climate Section- 8/23/2021)
• Better Markets explored the importance of ESG factors in a comprehensive report- White Paper: What Is ESG and Why Is It So Important? (7/14/2021)
• Better Markets filed substantive comments in response to the SEC’s request for information on climate related disclosures- Comment Letter: Climate Change Disclosures (6/14/2021)
• Better Markets lauded the leadership of CFTC Commissioners for their proactive climate policy- Letter: Better Markets Writes to CFTC Commissioners Praising Their Leadership in Addressing Climate-Related Risks (6/24/2021)
• We added new Members to the Better Markets Board to strengthen our climate change expertise- Press Release:  NCRC Membership, Policy and Equity Chief, Climate Change Tech Executive Join the Board of Directors (5/18/2021)

SEC

• Comment Letter: SEC Rules Will Help Provide Reliable and Comparable Information for the Growing Number of Investors Interested in ESG Funds (8/7/2022)
• Comment Letter: We Support the SEC’s Climate-Risk Disclosure Proposal, A Very Strong Measure That Can Be Made Even Better (6/17/2022)
• Press Release: We Welcome the SEC’s Climate Proposal Today, Which Recognizes Investors’ Need For Greater Disclosure (3/21/2022)
• Blog Post: Better Markets Responded to SEC Request for Public Input on Climate Disclosures (6/25/21)

Federal Reserve

• Fact Sheet: Banking Regulators Must Act Fast to Catch Up on Climate Financial Risk Management to Protect Main Street America (8/6/2024)
• Comment Letter: The Fed Begins to Tackle Climate Change Risks Building Up in the Big Banks (2/6/2023)
• Op-Ed: Better Markets Identifies The Real Threat To The Federal Reserve’s Independence From The Oil And Gas Industry in The Hill (3/14/2022)
• Report: The Agenda for the Fed’s Next Vice Chair for Supervision (Climate Related Arguments (10/7/2021)
• Report: Should Federal Reserve Chairman Jay Powell Be Reappointed? (Climate Section- 8/23/2021)
• White Paper: What Is ESG and Why Is It So Important? (7/14/2021)

FDIC

• Comment Letter: FDIC Takes Important Step Towards Managing Climate-Related Financial Risks (6/3/2022)

CFTC

• Comment Letter: CFTC’s Proposal Increasing Transparency In Carbon Credit Markets Is Crucial In The Fight Against Climate Change
• Comment Letter: CFTC Must Act Now to Protect America’s Families from the Real Risks Climate Change Poses to Their Lives and Livelihoods, as Detailed in Our Comment Letter (10/7/2022)
• Letter: Better Markets Writes to CFTC Commissioners Praising Their Leadership in Addressing Climate-Related Risks (6/24/2021)

OCC

• Comment Letter: Better Markets Applauds OCC Proposal to Incorporate Climate-Related Risks Into Bank Supervision & Assessment (2/14/2022)

Treasury

• Joint Letter: Better Markets Joins Coalition to Encourage Treasury Secretary Yellen to Name Senior, Experienced Climate Official (2/25/21)

Basel Committee

• Comment Letter: Better Markets Welcomes Basel Committee’s Inclusion Of Our Suggestions In Finalized Climate-Related Financial Risk Management Principles (6/22/2022)
• Comment Letter: Better Markets Endorses Basel Committee’s Proposed International Standards For Addressing Climate-Related Financial Risk (2/16/2022)

Media Hits

• US SEC to vote on long-awaited climate disclosure rule, notice says (2/29/24)

• Climate change raising risks of financial disaster for homeowners, insurers and bankers (The Hill- 8/30/23)

• Cracking Down on a Wall Street Trend: E.S.G. Makeovers (NY Times- 9/17/2022)
• Debate flares over possible climate guidance for small banks (E & E News- 6/7/2022)
• Fed Chair Powell Enjoys Support for Reappointment, but He’s Not a Lock (WSJ- 7/21/21)
• Who Should Provide ESG Assurance? (Reuters- 8/20/21)
• Analysis: Sustainable investing advocates hope for friendlier U.S. rules if Biden wins (Reuters- 11/2/2020))

Want to stay in the loop? Stay tuned. This page will be regularly updated with Better Markets’ latest analyses on the intersection of climate and finance.