The Office of the Comptroller of the Currency's (OCC) Acting Comptroller, Michael J. Hsu discussed climate risk management and diversity and inclusion, at the Institute of International Bankers Annual Washington Conference while certain US agencies published a statement on special purpose credit programs under the Equal Credit Opportunity Act and Regulation B.
The OCC Acting Comptroller noted that, later this year, OCC plans to finalize the principles on identification and management of climate-related financial risks for large banks (>USD 100 billion in assets) and then develop more detailed guidance. The plan is to do so on an interagency basis with the Federal Reserve Bank (FED) and the Federal Deposit Insurance Corporation (FDIC). OCC had proposed the draft principles in December 2021. After an appropriate transition period, the agencies (FDIC, FED, and OCC) will then begin assessing climate risk management capabilities of large banks. The US Agencies published an interagency statement.
Additionally, the interagency statement, from the US Agencies, on special purpose credit programs reminds creditors of the ability under the Equal Credit Opportunity Act and Regulation B to establish special purpose credit programs to meet the credit needs of specified classes of persons. These US Agencies are FDIC, FED, the Consumer Financial Protection Board (CFPB), the National Credit Union Administration, OCC, the U.S. Department of Housing and Urban Development (HUD), the U.S. Department of Justice, and the Federal Housing Finance Agency. The statement also calls attention to the recent HUD guidance concluding that special purpose credit programs instituted in conformity with Equal Credit Opportunity Act and Regulation B generally do not violate the Fair Housing Act. Accordingly, creditors may consider the use of special purpose credit programs across all types of credit covered by Equal Credit Opportunity Act and Regulation B. The agencies encourage creditors to explore opportunities to develop special purpose credit programs consistent with the Equal Credit Opportunity Act and Regulation B requirements as well as applicable safe and sound lending principles. Equal Credit Opportunity Act and Regulation B permit creditors to extend special purpose credit offered pursuant to any:
- credit assistance program expressly authorized by Federal or state law for the benefit of an economically disadvantaged class of persons
- credit assistance program offered by a not-for-profit organization for the benefit of its members or an economically disadvantaged class of persons
- special purpose credit program offered by a for-profit organization, or in which such an organization participates to meet special social needs, if it meets certain standards prescribed in regulations by CFPB
- News Release on Remarks by Michael J. Hsu
- Remarks of Michael J. Hsu (PDF)
- Notification on Special Purpose Credit Programs
- Statement on Special Purpose Credit Programs (PDF)
Keywords: Americas, US, Banking, Climate Change Risk, ESG, Lending, Special Purpose Credit Programs, Credit Risk, OCC, US Agencies
Dr. Denton provides industry leadership in the quantification of sustainability issues, climate risk, trade credit and emerging lending risks. His deep foundations in market and credit risk provide critical perspectives on how climate/sustainability risks can be measured, communicated and used to drive commercial opportunities, policy, strategy, and compliance. He supports corporate clients and financial institutions in leveraging Moody’s tools and capabilities to improve decision-making and compliance capabilities, with particular focus on the energy, agriculture and physical commodities industries.
Previous ArticleEC Regulation Amends Forms and Templates on Resolution Planning
The European Banking Authority (EBA) published the final draft regulatory technical standards specifying and, where relevant, calibrating the minimum performance-related triggers for simple.
The European Central Bank (ECB) is undertaking the integrated reporting framework (IReF) project to integrate statistical requirements for banks into a standardized reporting framework that would be applicable across the euro area and adopted by authorities in other EU member states.
The European Banking Authority (EBA) has been awarded the top European Standard for its environmental performance under the European Eco-Management and Audit Scheme (EMAS).
The Monetary Authority of Singapore (MAS) set out the Financial Services Industry Transformation Map 2025 and, in collaboration with the SGX Group, launched ESGenome.
The Basel Committee on Banking Supervision met, shortly after a gathering of the Group of Central Bank Governors and Heads of Supervision (GHOS), the oversight body of BCBS.
The International Organization of Securities Commissions (IOSCO) welcomed the work of the international audit and assurance standard setters—the International Auditing and Assurance Standards Board (IAASB)
The Bank of England (BoE) published a Statistical Notice (2022/18), which informs that due to the Bank Holiday granted for Her Majesty Queen Elizabeth II’s State Funeral on Monday September 19, 2022.
The French Prudential Control and Resolution Authority (ACPR) announced that the European Banking Authority (EBA) has updated its filing rules and the implementation dates for certain modules of the EBA reporting framework 3.2.
The European Central Bank (ECB) published a paper that examines how credit rating agencies accepted by the Eurosystem, as part of the Eurosystem Credit Assessment Framework (ECAF)
The Australian Prudential Regulation Authority (APRA) announced reduction in the aggregate Committed Liquidity Facility (CLF) for authorized deposit-taking entities to ~USD 33 billion on September 01, 2022.