Thank you, Chairman Gruenberg, for taking up the issue of climate change and banks.

Banks' continued investments in fossil fuels are driving climate change–a crisis that puts our financial system, people of color and low-income communities, and our planet at risk.

Regulators must not let financial institutions gamble with our future. We need you to push banks to take the urgent steps necessary to address the dangers they face from climate change, and stop their short-term business decisions from endangering our economy and communities.

I support the proposed guidance’s recommendations to banks that they:

Incorporate climate-related risk management into every level of business;

Plan for climate change over a long time horizon, and update models as additional data becomes available;

Develop clear definitions of possible climate-related risk exposures, and metrics for setting limits;

Make sure that their internal strategies are consistent with their public-facing climate commitments; and

Avoid risk management strategies that disproportionately harm disadvantaged communities.

The FDIC must ensure that banks’ actions match their commitments to zeroing out their net carbon emissions. Banks’ management of climate-related risk should be factored into their supervisory ratings, too.

It is in the best interest of both the public and banks themselves to act now to minimize climate-related risk. The FDIC must use the full extent of its authority to issue strong final guidance to banks on climate risk, continue to protect against unsafe and unsound bank practices, and require remedies from banks where appropriate.