Climate Risk Scorecard
Notable Progress
Some Progress
No Progress
Not Applicable
National Credit Union Association
Notable Progress
Reasoning
For more information about our key findings and learnings, please download the 2024 Climate Risk Scorecard report.
Some Progress
Reasoning
For more information about our key findings and learnings, please download the 2024 Climate Risk Scorecard report.
Methodology
We assessed the extent to which the agency has expanded and established sustainable, well-resourced capacity “to define, identify, measure, monitor, assess, and report on climate-related financial risks and their effects on financial stability.” (FSOC 1.3).Â
This includes investments in staffing, appointing senior staff, forming internal working groups and/or committees, staff training, investments in technological and analytical capabilities, and financial resources provided to staff working on these issues.Â
Some Progress
Reasoning
For more information about our key findings and learnings, please download the 2024 Climate Risk Scorecard report.
Methodology
We assessed the extent to which the agencies have made information and data available to the public.Â
“[I]nclude descriptions of their activities related to climate-related financial risks in their annual reports and consider incorporating climate-related financial risks in relevant risk reports that they publish, as appropriate ... [and] within the context of each member’s mandate and authority.” (FSOC 1.4).Â
“[M]ake climate-related data for which they are the custodians freely available to the public, as appropriate and subject to any applicable data confidentiality requirements.” (FSOC 1.5).Â
Some Progress
Reasoning
For more information about our key findings and learnings, please download the 2024 Climate Risk Scorecard report.
Methodology
We assessed the extent to which the agency - consistent with its mandate and authorities and its membership in the Financial Literacy and Education Commission (FLEC) - has assessed and made progress on addressing climate risks to financially vulnerable communities. Â
“[C]oordinate the analyses of climate-related financial risks ... with their efforts to understand impacts on communities and households. FSOC members should, as applicable, integrate these analyses into the[ir annual] public reports.” (FSOC 1.6).Â
“[E]valuate climate-related impacts and the impacts of proposed policy solutions on financially vulnerable populations when assessing the impact of climate change on the economy and the financial system.” (FSOC 1.8). Â
“[FLEC members should] analyze and understand the impact of climate change on the financial well-being of financially vulnerable populations. FSOC members that are also FLEC members should actively participate in this analysis.” FLEC members include the Fed, OCC, FDIC, NCUA, SEC, CFTC, and FHFA. (FSOC 1.9). Â
Some Progress
Reasoning
For more information about our key findings and learnings, please download the 2024 Climate Risk Scorecard report.
Methodology
We assessed the extent to which the agencies have advanced research and data collection on climate risk. Â
“Identify[] the data needed to evaluate the climate-related financial risk exposures of regulated entities and financial markets.” (FSOC 2.1).  Â
“Perform[] an internal inventory of currently collected and procured data and its relevance for climate risk assessments." (FSOC 2.1).  Â
“Develop[] a plan for procuring necessary data through data collection, data sharing arrangements and information purchased from data providers or other sources.” (FSOC 2.1).  Â
“[F]acilitate the sharing of climate-related data across FSOC members and non-FSOC member agencies to assess climate-related financial risk, consistent with data confidentiality requirements.” (FSOC 2.2)   Â
“[D]evelop consistent data standards, definitions, and relevant metrics ... to facilitate common definitions of climate-related data terms, sharing of data, and analysis and aggregation of data.” (FSOC 2.5)Â
Some Progress
Reasoning
For more information about our key findings and learnings, please download the 2024 Climate Risk Scorecard report.
Methodology
We assessed the extent to which the agencies have begun to assess, develop, and conduct climate scenario analyses at their supervised entities. Â
“[C]ollaborate with external experts to identify climate forecasts, scenarios, and other tools necessary to better understand the exposure of regulated entities to climate-related risks and how those risks translate into economic and financial impacts.” (FSOC 4.1).Â
“[U]se scenario analysis, where appropriate, as a tool for assessing climate-related financial risks, taking into account their supervisory and regulatory mandates and the size, complexity, and activities of regulated entities.” (FSOC 4.3).Â
“[C]onsider using common scenarios that build on existing work, including scenarios developed by NGFS and work at the FSB, as appropriate for the institutions and markets under consideration.” (FSOC 4.4).Â
No Progress
Reasoning
For more information about our key findings and learnings, please download the 2024 Climate Risk Scorecard report.
Methodology
We assessed the extent to which the agency has enhanced public reporting requirements for their regulated entities. The market is currently mispricing climate risk. The lack of consistent disclosure by entities supervised by U.S. financial regulators is an obstacle to market efficiency and to the accurate pricing of climate risk. Â
“[R]eview their existing public disclosure requirements and consider, as appropriate, updating them to promote the consistency, comparability, and decision-usefulness of information on climate-related risks and opportunities.” (FSOC 3.1).Â
“[C]onsider enhancing public reporting requirements for climate related risks in a manner that builds on the four core elements of the TCFD.” (FSOC 3.2).Â
“[C]onsider whether such disclosures should include disclosure of GHG emissions.” (FSOC 3.4).Â
“[R]eview banks’ public regulatory reporting requirements to assess whether enhancements are needed to provide market participants with information on institutions’ climate-related financial risks, taking into account a bank’s size, complexity, and activities.” (FSOC 3.7).Â
Some Progress
Reasoning
For more information about our key findings and learnings, please download the 2024 Climate Risk Scorecard report.
Methodology
We assessed the extent to which the agencies have enhanced supervisory scrutiny of climate risk management at their supervised entities to ensure their resilience and the resilience of our financial system.                Â
“[C]larif[y] or enhanced risk management expectations ... [and] guidance.” (FSOC 4.8).Â
“[R]eview[] regulated entities’ efforts to address climate-related risks." (FSOC 4.6).
“[R]eview[] existing ... guidance ... to identify where clarifications and enhancements are needed.” (FSOC 4.7).Â
No Progress
Reasoning
For more information about our key findings and learnings, please download the 2024 Climate Risk Scorecard report.
Methodology
We assessed the extent to which the agencies have incorporated climate risk management expectations into their regulatory requirements for supervised entities to ensure their resilience and the resilience of our financial system.
“[C]larif[y] or enhanced risk management ... requirements.” (FSOC 4.8).Â
“[R]eview[] existing regulations ... and regulatory reporting to identify where clarifications and enhancements are needed.” (FSOC 4.7).Â
Notable Progress
Reasoning
Since last year’s assessment, the NCUA has delivered several remarks publicly acknowledging the systemic nature of climate-related financial risk:
Chair Todd Harper statement at the NCUA Board meeting discussing the climate-related financial risk RFI (April 2023)
Climate-Related Financial Risk Working Group Co-Chair Rachel Cononi testimony at the NCUA Board meeting discussing the climate-related financial risk RFI (April 2023)
Climate-Related Financial Risk Working Group Co-Chair Lisa Roberson testimony at the NCUA Board meeting discussing the climate-related financial risk RFI (April 2023)
In addition to these public remarks and publications, Ceres is aware of individual board members who have offered alternative views on the relevance, extent, or urgency of climate-related financial risks.
Additionally, the NCUA has included the risks presented by climate change to the financial system its 2023 Supervisory Priorities and 2022 Annual Report. Importantly, in April 2023, the NCUA published a request for information (RFI) on climate-related financial risks to federally-insured credit unions.
Next Steps
Continue to publicly acknowledge the systemic nature of climate-related financial risk in agency speeches and publications. Â
*These recommendations, all within the NCUA’s mandate and authority, are designed to address climate-related financial risks and protect our credit unions, financial system and communities.Â
Methodology
We assessed the extent to which the agency has publicly affirmed the systemic nature of the climate crisis individually in official agency communications (outside of the FSOC report).Â
Some Progress
Reasoning
The FSOC’s 2021 report on climate-related financial risk describes the NCUA’s Climate-Related Financial Risk Working Group as being “composed of senior staff members from across the agency.” During the NCUA’s April 2023 Board meeting, at which the climate-related financial risk RFI was approved, Rachel Cononi and Lisa Roberson were identified as the working group’s co-chairs. However, further information on the working group staff and research is not yet available publicly.
Next Steps
Announce the establishment of NCUA’s Climate-Related Financial Risk Working Group and co-chairs.Â
Appoint and announce staff assigned to the working group.Â
Continue work within the CFRAC, FLEC, NGFS, and other interagency climate risk working groups, particularly the Fed, OCC, and FDIC.Â
Initiate internal staff education and training on climate-related financial risks. Â
Train credit union examiners on climate-related financial risk and how these risks fit within existing risk frameworks, including identification of risks specific to LMI communities in which credit unions are uniquely positioned to address.Â
Support expansion of credit union internal climate risk management capacity.Â
Establish and announce an internal plan for how the NCUA will address climate-related financial risk to its regulated financial institutions, including goals and priorities. Â
*These recommendations, all within the NCUA’s mandate and authority, are designed to address climate-related financial risks and protect our credit unions, financial system and communities.Â
Methodology
We assessed the extent to which the agency has expanded and established sustainable, well-resourced capacity “to define, identify, measure, monitor, assess, and report on climate-related financial risks and their effects on financial stability.” (FSOC 1.3).Â
This includes investments in staffing, appointing senior staff, forming internal working groups and/or committees, staff training, investments in technological and analytical capabilities, and financial resources provided to staff working on these issues.Â
Some Progress
Reasoning
In its 2023 Supervisory Priorities letter, the NCUA flagged that its consumer financial protection activities will include reviewing the impacts of climate-related financial risk on credit unions. Similarly, the NCUA’s 2022 Annual Report included climate-related financial risk as an area of focus for 2023. The agency noted it will need to enhance its understanding of these impacts, but stated that credit unions are best positioned to assess these risks.
However, the NCUA does not have a dedicated webpage for its Climate-Related Financial Risk Working Group or provide regular updates on its work or outcomes outside of its scheduled, cumulative reports and assessments.
Next Steps
Establish a designated webpage to provide updates on completed and ongoing climate risk-related activities, including what the work the NCUA has undertaken, staff assigned to the issue, what budget and resources are allocated for the work, and other recommendations in this section. Â
*These recommendations, all within the NCUA’s mandate and authority, are designed to address climate-related financial risks and protect our credit unions, financial system and communities.Â
Methodology
We assessed the extent to which the agencies have made information and data available to the public.Â
“[I]nclude descriptions of their activities related to climate-related financial risks in their annual reports and consider incorporating climate-related financial risks in relevant risk reports that they publish, as appropriate ... [and] within the context of each member’s mandate and authority.” (FSOC 1.4).Â
“[M]ake climate-related data for which they are the custodians freely available to the public, as appropriate and subject to any applicable data confidentiality requirements.” (FSOC 1.5).Â
Some Progress
Reasoning
At its annual DEI Summit in November 2022, the NCUA hosted a panel on opportunities for credit unions to incorporate environmental justice and climate resiliency. The NCUA’s April 2023 RFI on climate-related financial risk also includes discussion of the risks that disproportionately impact low-income and minority communities, as well as three questions specific to financially vulnerable communities.
The NCUA indicated to Ceres that it participates with the FLEC Climate Resilience Group to study climate-related financial impacts on households, including financially vulnerable households, although this involvement is not indicated on the agency’s website and no research from the FLEC group is publicly available.
Next Steps
Actively and transparently engage in interagency coordination on assessing risk to financially vulnerable communities, provide updates, and publish findings, such as advances made with the FLEC Climate Resiliency Group.Â
Consider the policy implications of climate-related financial risk supervision and regulation on LMI and BIPOC communities.Â
Provide recommendations and guidance to federally-insured credit unions on how to assess climate-related financial risks specific to vulnerable and underserved communities and how to avoid inadvertently engaging in discriminatory practices (i.e. bluelining). Â
*These recommendations, all within the NCUA’s mandate and authority, are designed to address climate-related financial risks and protect our credit unions, financial system and communities.Â
Methodology
We assessed the extent to which the agency - consistent with its mandate and authorities and its membership in the Financial Literacy and Education Commission (FLEC) - has assessed and made progress on addressing climate risks to financially vulnerable communities. Â
“[C]oordinate the analyses of climate-related financial risks ... with their efforts to understand impacts on communities and households. FSOC members should, as applicable, integrate these analyses into the[ir annual] public reports.” (FSOC 1.6).Â
“[E]valuate climate-related impacts and the impacts of proposed policy solutions on financially vulnerable populations when assessing the impact of climate change on the economy and the financial system.” (FSOC 1.8). Â
“[FLEC members should] analyze and understand the impact of climate change on the financial well-being of financially vulnerable populations. FSOC members that are also FLEC members should actively participate in this analysis.” FLEC members include the Fed, OCC, FDIC, NCUA, SEC, CFTC, and FHFA. (FSOC 1.9). Â
Some Progress
Reasoning
The NCUA established Climate-Related Financial Risk Working Group “with the goal of further incorporating climate-related financial risks into the agency’s risk-monitoring framework.” In September 2022, this working group partnered with the Federal Emergency Management Agency and Hope Credit Union to hold a webinar on how credit unions can prepare for and build resiliency to climate-related disasters. In April 2023, this working group published a Research Note examining credit union exposure to climate-related physical risks. No details on the working group’s composition or research agenda is publicly available and the working group does not have a designated webpage.
The NCUA’s 2022 Annual Report also noted that it is participating in FSOC’s Climate-Related Financial Risk Committee and is collaborating with other financial regulators. NCUA personnel indicated to Ceres that participating staff are working to identify and inventory relevant data, develop data standards, relevant metrics and analytic tools, and facilitate data sharing.
Next Steps
Provide updates on the agency’s climate risk-related data collection and research, what additional data is needed, and its plan for collecting such data.Â
Provide easily searchable access to research notes, blogs, infographics, etc. that demonstrate data collection and research on climate-related financial risk.Â
Issue a request for information on available data, models, or other information that could be used, in addition to existing data, to inform the agencies on climate-related risks to the financial system and the economy, including data on the adverse financial effects of climate on LMI communities.Â
Conduct a horizontal review of federally-insured credit unions with significant exposure to climate risk to gain a better understanding of strategies and practices for risk identification and management, grouping credit unions with large exposures to climate risk or credit unions with loan concentrations in particularly vulnerable geographic areas. Â
Conduct a climate risk policy sprint with FFIEC members to develop common definitions and review current and evolving risks to financial institutions. Â
Develop a Climate Risk Assessment Tool similar to the Cybersecurity Assessment Tool with FFIEC members to help credit unions (particularly smaller, community institutions) identify their climate-related financial risks associated as well as their preparedness under various climate scenarios and actionable steps to mitigate risks.Â
*These recommendations, all within the NCUA’s mandate and authority, are designed to address climate-related financial risks and protect our credit unions, financial system and communities.Â
Methodology
We assessed the extent to which the agencies have advanced research and data collection on climate risk. Â
“Identify[] the data needed to evaluate the climate-related financial risk exposures of regulated entities and financial markets.” (FSOC 2.1).  Â
“Perform[] an internal inventory of currently collected and procured data and its relevance for climate risk assessments." (FSOC 2.1).  Â
“Develop[] a plan for procuring necessary data through data collection, data sharing arrangements and information purchased from data providers or other sources.” (FSOC 2.1).  Â
“[F]acilitate the sharing of climate-related data across FSOC members and non-FSOC member agencies to assess climate-related financial risk, consistent with data confidentiality requirements.” (FSOC 2.2)   Â
“[D]evelop consistent data standards, definitions, and relevant metrics ... to facilitate common definitions of climate-related data terms, sharing of data, and analysis and aggregation of data.” (FSOC 2.5)Â
No Progress
Reasoning
Ceres is not aware of any progress in this category.
Next Steps
Design and conduct climate scenario analysis exercises with credit unions to assess safety and soundness and ability to withstand climate impacts, starting with those over $15 billion in assets, and eventually extending to all federally insured credit unions irrespective of asset size. Â
Conduct climate scenario analysis exercises and stress tests that include physical and transition risks, disorderly transition, concurrent and consecutive risks, insurance gaps, impacts on multiple traditional risk categories, short- and long-term horizons, etc.Â
Increase capital requirements or buffers where the results indicate insufficient levels to absorb losses.Â
*These recommendations, all within the NCUA’s mandate and authority, are designed to address climate-related financial risks and protect our credit unions, financial system and communities.Â
Methodology
We assessed the extent to which the agencies have begun to assess, develop, and conduct climate scenario analyses at their supervised entities. Â
“[C]ollaborate with external experts to identify climate forecasts, scenarios, and other tools necessary to better understand the exposure of regulated entities to climate-related risks and how those risks translate into economic and financial impacts.” (FSOC 4.1).Â
“[U]se scenario analysis, where appropriate, as a tool for assessing climate-related financial risks, taking into account their supervisory and regulatory mandates and the size, complexity, and activities of regulated entities.” (FSOC 4.3).Â
“[C]onsider using common scenarios that build on existing work, including scenarios developed by NGFS and work at the FSB, as appropriate for the institutions and markets under consideration.” (FSOC 4.4).Â
No Progress
Reasoning
Ceres is not aware of any progress in this category.
Next Steps
Amend uniform disclosure systems such as the Call Report with other FFIEC members. Â
Amend the Financial Performance Report to create standardized measurements of climate risk at individual credit unions as well as risks among peer groups and in the aggregate, allowing examiners to assess a credit union’s financial condition and risks and to compare an institution with its peers. Â
*These recommendations, all within the NCUA’s mandate and authority, are designed to address climate-related financial risks and protect our credit unions, financial system and communities.Â
Methodology
We assessed the extent to which the agency has enhanced public reporting requirements for their regulated entities. The market is currently mispricing climate risk. The lack of consistent disclosure by entities supervised by U.S. financial regulators is an obstacle to market efficiency and to the accurate pricing of climate risk. Â
“[R]eview their existing public disclosure requirements and consider, as appropriate, updating them to promote the consistency, comparability, and decision-usefulness of information on climate-related risks and opportunities.” (FSOC 3.1).Â
“[C]onsider enhancing public reporting requirements for climate related risks in a manner that builds on the four core elements of the TCFD.” (FSOC 3.2).Â
“[C]onsider whether such disclosures should include disclosure of GHG emissions.” (FSOC 3.4).Â
“[R]eview banks’ public regulatory reporting requirements to assess whether enhancements are needed to provide market participants with information on institutions’ climate-related financial risks, taking into account a bank’s size, complexity, and activities.” (FSOC 3.7).Â
Some Progress
Reasoning
The NCUA’s RFI on Climate-Related Financial Risk broadly outlines the physical and transition impacts credit unions may face from climate-related financial risk and requests feedback on multiple topics, including governance, risk management, and opportunities. However, the RFI is not draft supervisory guidance, and specifically states that “information provided by credit unions as part of this RFI will not be used in the examination and supervision of individual credit unions” and “new requirements for credit unions associated with climate-related financial risk would require changes to examination and supervision procedures and Board action and approval before implementing.” The RFI also notes that it is seeking input that will strengthen its risk management supervision, but there is no indication whether supervisory guidance or regulations will be published as a result of the information collected.
Next Steps
Issue detailed guidance for all federally insured credit unions on climate risk management following closure of its request for information on climate-related financial risk. Â
Ensure guidance contemplates smaller credit unions and CDFIs, accounting for the unique risks (i.e. geographic and sectoral concentration) these institutions face, while tailoring guidance to reflect these differences and supporting the education of boards and management on climate risk and why it matters to their credit union.Â
Issue guidance through the FFIEC to raise awareness of climate risks, encourage credit unions to integrate climate risks into their risk frameworks, and provide guidance on how to measure and mitigate risks, including through best practices.Â
Incorporate the identification and management of climate-related financial risks based on established risk factors into the Examiner’s Guide.Â
Explicitly integrate climate risk into CAMELS ratings, the seven supervisory risk categories, and credit union examinations. Â
Integrate climate-related risk management into the process for chartering new credit unions.Â
*These recommendations, all within the NCUA’s mandate and authority, are designed to address climate-related financial risks and protect our credit unions, financial system and communities.Â
Methodology
We assessed the extent to which the agencies have enhanced supervisory scrutiny of climate risk management at their supervised entities to ensure their resilience and the resilience of our financial system.                Â
“[C]larif[y] or enhanced risk management expectations ... [and] guidance.” (FSOC 4.8).Â
“[R]eview[] regulated entities’ efforts to address climate-related risks." (FSOC 4.6).
“[R]eview[] existing ... guidance ... to identify where clarifications and enhancements are needed.” (FSOC 4.7).Â
No Progress
Reasoning
Ceres is not aware of any progress in this category.
Next Steps
Propose and issue detailed regulations for climate-related financial risk management requirements.Â
*These recommendations, all within the NCUA’s mandate and authority, are designed to address climate-related financial risks and protect our credit unions, financial system and communities.Â
Methodology
We assessed the extent to which the agencies have incorporated climate risk management expectations into their regulatory requirements for supervised entities to ensure their resilience and the resilience of our financial system.
“[C]larif[y] or enhanced risk management ... requirements.” (FSOC 4.8).Â
“[R]eview[] existing regulations ... and regulatory reporting to identify where clarifications and enhancements are needed.” (FSOC 4.7).Â
Notable Progress
Reasoning
NCUA chairman Todd M. Harper has identified climate as a systemic risk to the financial system in public speeches. In his August 2021 testimony before the Senate Banking Committee, he emphasized how regulators, including the NCUA, have a responsibility to foster systemic resiliency to all material risks, including those related to climate change. Â
Climate-related financial risks were included in several NCUA publications, including the NCUA’s 2021 Annual Report, 2022-2023 Budget Justification, and 2022-2026 Strategic Plan, discussing how the physical and transition risks posed by climate represent “significant risks to the U.S. economy and the U.S. financial system.”Â
Methodology
Recognizing that climate change poses a financial stability risk is a critical first step for all financial regulators and will send an important message to all financial market stakeholders. Such statements are particularly important, given the complex nature of climate risks and continuing ambiguities about the extent to which the issue falls under specific agency mandates.Â
We assessed the extent to which the agency has publicly affirmed the systemic nature of the climate crisis individually in official agency communications outside of the FSOC report.Â
Some Progress
Reasoning
The FSOC’s 2021 report on climate-related financial risk mentioned a recently established Climate Financial Risk Working Group within the NCUA, “with the goal of further incorporating climate-related financial risks into the agency’s risk-monitoring framework.” Ceres was unable to find details on the working group’s work and progress in the public record.Â
In its 2022 Annual Performance Plan, the NCUA made public its goal to publish by the end of 2022 a request for information (RFI) seeking public input from credit union stakeholders regarding climate-related financial risks. The findings of the RFI are expected to help the working group identify climate risk-related data gaps and produce new guidance for credit unions.Â
The FSOC’s 2021 report also notes that the NCUA will consider how to model and estimate climate-related risks to the National Credit Union Share Insurance Fund (NCUSIF) through a request for information that will gather input from credit unions and other stakeholders. Ceres was unable to find updates on the status of this effort.Â
NCUA personnel has indicated to Ceres that the agency has dedicated staff actively participating in FSOC Climate Financial Risk Committee workstreams to identify and inventory relevant data, develop data standards, relevant metrics and analytic tools, and facilitate data sharing.Â
Methodology
Producing quality research and data is critical to assessing and addressing climate-related financial risks. As stated in the FSOC report, “Analyzing climate-related financial risks begins with measuring and assessing risks from climate impacts. To do this, data is needed that captures the drivers of physical and transition risks that could impact households, businesses, the economy, and the financial sector (page 48).” We incorporated this new category in the 2022 Scorecard to respond to these critical data gaps.Â
We assessed the extent to which the agency has advanced work to make progress on FSOC Recommendation 2.1:Â Â
“Identif[y] the data needed to evaluate the climate-related financial risk exposures of regulated entities and financial markets within the context of each FSOC member’s mandate and authorities; Â
Perfor[m] an internal inventory of currently collected and procured data and its relevance for climate risk assessments; and Â
Develo[p] a plan for procuring necessary data through data collection, data sharing arrangements and information purchased from data providers or other sources.”Â
No Progress
Reasoning
Ceres is unaware of any work the NCUA has carried out to assess the risks posed by climate to financially vulnerable communities. The NCUA is a member of the Financial Literacy and Education Commission (FLEC) (FSOC Recommendations 1.8 and 1.9).Â
In feedback provided to Ceres, NCUA stated that, through its participation with the FLEC Climate Resilience Group, the NCUA is studying climate-related financial impacts on households, including financially vulnerable households. The information obtained through the agency’s participation will inform future efforts to assess climate risks in financially vulnerable communities.Â
Next Steps
Outline the NCUA’s involvement in FLEC and its work on assessing the resilience of financially vulnerable populations. Â
*These recommendations, all within the NCUA’s mandate and authority, are designed to address climate-related financial risks and protect our credit unions, financial system and communities.Â
Methodology
The FSOC report highlights the imperative to assess climate risks on “financially vulnerable communities,” given that “climate change disproportionately affects financially vulnerable populations potentially including lower-income communities, communities of color, Native American communities, and other disadvantaged or underserved communities.” This troubling reality is further compounded by the fact that vulnerable communities are “less likely to have the resources to protect and guard against damage to their properties or adequately deal with loss of income from an adverse climate or weather event (page 22).” While the significance of this issue is emphasized, it is qualified by an important warning against measures or actions that may unintentionally worsen existing inequalities.Â
We assessed the extent to which each agency, consistent with its mandate, authorities, and its membership in the Financial Literacy and Education Commission (FLEC), has advanced work to make progress on FSOC Recommendations 1.8 and 1.9: Â
“members, consistent with their mandates and authorities, evaluate climate-related impacts and the impacts of proposed policy solutions on financially vulnerable populations when assessing the impact of climate change on the economy and the financial system.” (FSOC 1.8)Â
“Treasury Department engage other members of the Financial Literacy and Education Commission (FLEC) to analyze and understand the impact of climate change on the financial well-being of financially vulnerable populations. FSOC members that are also FLEC members should actively participate in this analysis.” (FSOC 1.9). Â
FLEC members include the Office of the Comptroller of the Currency, Federal Reserve, the Federal Deposit Insurance Corporation, National Credit Union Administration, Securities and Exchange Commission, Commodity Futures Trading Commission. Â
Some Progress
Reasoning
The FSOC’s 2021 report on climate-related financial risk describes the NCUA’s Climate Financial Risk Working Group as being “composed of senior staff members from across the agency.” Â
Discussions with agency personnel confirm that specific staff are focused on climate change, but information on the individuals or the composition of the working group is not yet found in the public domain.Â
Next Steps
Dedicate a page on the NCUA’s website to its work on climate risk, featuring the work of the NCUA’s Climate Financial Risk Working Group. Â
Increase the transparency around the working group’s mission, work, composition, and progress to date. Â
*These recommendations, all within the NCUA’s mandate and authority, are designed to address climate-related financial risks and protect our credit unions, financial system and communities.Â
Methodology
It is urgent that agencies establish sustainable, well-resourced capacity at the political and technical levels to address climate risk to meet the scale of the challenge and deliver on the administration and FSOC commitments.
We assessed the extent to which the agency has appointed dedicated staff to address climate risk to execute the agency’s climate commitments and FSOC recommendations. We assess, for example, the role, authority, and human and financial resources provided to staff dedicated to work on climate risk.Â
No Progress
Reasoning
Ceres is unaware of any work the NCUA has carried out to bolster climate-related disclosure. Although the NCUA has the authority to amend uniform disclosure systems such as the Call Report with other Federal Financial Institutions Examinations Council (FFIEC) members, there is no public information to indicate any action in this area.Â
Methodology
The market is currently mispricing climate risk. The lack of consistent disclosure by entities supervised by U.S. financial regulators is an obstacle to market efficiency and to the accurate pricing of climate risk. In response, the FSOC recommended that members:Â
“review their existing public disclosure requirements and consider, as appropriate, updating them to promote the consistency, comparability, and decision-usefulness of information on climate-related risks and opportunities, consistent with their mandates and authorities.” (FSOC 3.1) Â
“consider enhancing public reporting requirements for climate related risks in a manner that builds on the four core elements of the Task Force on Climate-Related Financial Disclosure (TCFD)” (FSOC 3.2)Â
“consider whether such disclosures should include disclosure of GHG emissions” (FSOC 3.4)Â
Following on FSOC Recommendations 3.1, 3.2, 3.3, and 3.4, we assessed the extent to which the agency has enhanced public reporting requirements, consistent with its statutory mandates.Â
Some Progress
Reasoning
The NCUA addressed climate-related financial risks in its draft 2022-2026 Draft Strategic Plan, noting that “the agency will need to adapt its risk monitoring framework to account for climate-related threats to financial stability, the credit union system, and the Share Insurance Fund.” The forthcoming request for information may contribute positively to the NCUA’s capacity to understand the potential impacts of climate risk on credit unions and its eventual development of supervisory and regulatory tools.Â
According to the FSOC’s 2021 report on climate-related financial risk, the NCUA’s Climate Financial Risk Working Group is currently evaluating the agency’s existing regulatory tools and assessing whether the current risk-monitoring framework is adequate for managing climate-related financial risks. Ceres found no information on the agency’s progress on this front in the public domain.Â
Next Steps
Describe the NCUA’s involvement in the FFIEC. Â
Modernize risk definitions as part of the credit supervision process to include climate risk as a standalone category or articulate it more explicitly throughout the seven established risk categories (as per the recommendations in Ceres’ Turning Up the Heat report). Â
Integrate guidance on climate-informed supervision into the examination manual and the process for chartering new credit unions (as per the recommendations in Ceres’ Turning Up the Heat report).Â
*These recommendations, all within the NCUA’s mandate and authority, are designed to address climate-related financial risks and protect our credit unions, financial system and communities. Â
Methodology
Supervision and regulation of climate risk is urgently needed to ensure the resilience of supervised entities and our financial system. Â
Following FSOC Recommendations, we assessed the extent to which the agency has “clarified or enhanced risk management expectations, guidance and requirements (FSOC 4.8).” We will also consider if agencies have:Â
“reviewed regulated entities’ efforts to address climate-related risks (FSOC 4.6)Â
“reviewed existing regulations, guidance and regulatory reporting to identify where clarifications and enhancements are needed” (FSOC 4.7)Â
The National Credit Union Administration (NCUA) is an “independent federal agency that insures deposits at federally insured credit unions, protects the members who own credit unions, and charters and regulates federal credit unions.” This agency monitors over 4,903 federally insured credit unions with 131.0 million members. Â
The NCUA’s mission is to ensure a safe credit union system. It does so by insuring shares (deposits) at all covered entities (credit unions), establishing rules and expectations for credit unions to follow, and mandating annual reports from credit unions. Â
There are various areas under the NCUA’s mission where it could act to affirm and address climate risk. Other banking regulators, including the Federal Reserve, have taken initial steps to assess how climate change can affect their covered institutions. The NCUA could follow suit for credit unions and develop guidance on how they should integrate climate change into their risk management, internal controls, business strategies, governance, and disclosure practices. Additionally, the NCUA could leverage its connection with the Federal Financial Institutions Examinations Council (FFIEC) to modernize risk definitions as part of the supervision process (including supervision manuals) and influence best practices on climate risk management among the largest credit unions.
Never miss an alert
Sign up for the latest news and updates from Ceres.