On February 6, ISDA and the Securities Industry and Financial Markets Association (SIFMA) submitted a joint response to the Federal Reserve Board (FRB) on the Principles for Climate-related Financial Risk Management for Large Banks. The associations appreciate the FRB’s intent to closely align the proposed principles with the proposed climate-related financial risk consultations issued by both the Office of the Comptroller of the Currency (OCC) and the Federal Deposit Insurance Corporation (FDIC). Given the intensifying pace of climate change, it is important to have a continuous dialogue with banking regulators to develop the best approach to the treatment of climate-related financial risks.
With a few exceptions highlighted in our response, our comments on the proposed principles are similar to the comments we provided in response to the OCC and the FDIC’s proposals. The associations support the US Agencies’ goal to ensure the safe management of banks’ exposures to climate-related financial risks. We support public sector efforts to establish regulatory principles and guidance surrounding climate-related financial risks that is consistent with the existing risk management operational framework.
Documents (1) for ISDA-SIFMA Respond to FRB on Principles for Climate-related Financial Risk Management for Large Banks
Latest
ISDA In Review – August 2026
A compendium of links to new documents, research papers, press releases and comment letters published by ISDA in August 2026.
Remove Bureaucracy from Cross-margin Approvals
Cross-margining programs play a critical role in financial markets. By ensuring margin requirements more closely reflect the actual risk of a portfolio of products, they reduce liquidity strain and improve market efficiency, both of which will become even more important...
Joint Response on CCP Resolution
On September 7, ISDA and FIA responded to a Bank of England (BOE) discussion paper on central counterparty (CCP) resolution. The associations support greater clarity on valuation capabilities prior to a crisis scenario and the boundary between recovery and resolution,...
Expanding Legal Agreement Coverage in the CDM
This paper examines the recent extension of the Common Domain Model (CDM)1 to represent two of the most significant, and previously undeveloped, areas of its legal agreement model: umbrella agreements and contract amendments. Umbrella agreements are widely used to document...