The OCC’s Proposed Principles for Climate Risk Management by Large Banks: Ten Things to Know

On December 16, 2021, the Office of the Comptroller of the Currency (“OCC”) issued draft principles (the “Proposal”) on the identification and management of climate-related financial risks by OCC-supervised banks with more than $100 billion in total consolidated assets (“covered banks”). The Proposal is intended to provide a high-level framework for the safe and sound management of climate-related financial risks by covered banks and will serve as the basis for more detailed guidance applicable to all OCC-supervised banks.