U.S. Treasury Takes Steps to Combat Climate Change

This blog was coauthored by Elizabeth Sisul and Nick Bohmann.

As Guidehouse has noted in previous blog posts, regulators overseeing the US financial system under the Biden administration are focusing on climate change. The U.S. Department of the Treasury (U.S. Treasury) recently took concrete steps that reflect its commitment to combating the climate crisis.  

Treasury’s Climate Action Plan

On October 7, 2021, U.S. Treasury released a Climate Action Plan (CAP) in accordance with Executive Order 14008 to increase the department’s resiliency in the face of climate change. In announcing the CAP, Treasury Secretary Janet Yellen said, “Climate change isn’t just a specter on the horizon… It is a present challenge, and we must adapt.” The CAP, which focuses on internal changes U.S. Treasury can make to mitigate climate risks to its operations, consists of five priority action areas:

1. Rebuild programs and capabilities that might have atrophied or stagnated.
2. Address climate change impacts and vulnerabilities across the range of U.S. Treasury operations including administrative, manufacturing, and law enforcement activities.
3. Ensure a climate-focused approach to managing the U.S. Treasury’s real property portfolio footprint.
4. Enable procurement management to fully consider climate change realities.
5. Provide, measure, and account for a financial investment approach appropriate to the U.S. Treasury’s climate objectives.

The CAP’s scope is wide-ranging and includes mitigating vulnerabilities to physical assets and supply chains, ensuring transparency of climate resilience investments, and educating management and staff on climate risks. These areas of internal focus could form a basis for future guidance to the banking system.   

Saule Omarova Nominated as Comptroller of the Currency

On September 23, 2021, President Biden nominated Cornell University law professor Saule Omarova as comptroller of the currency. Omarova has criticized big banking, and environmental groups have applauded the nomination, anticipating that she will make combating climate risk a priority. In September, acting Comptroller Michael Hsu said that the Office of the Comptroller of the Currency (OCC) is “focused on developing effective climate risk management guidance for large banks, working with our interagency peers.” Omarova is likely to carry out this agenda if her nomination is approved.  

Although the U.S. Treasury’s CAP does not propose specific regulations for financial institutions, it is a reflection of the U.S. Treasury’s climate change priorities and could offer insight into how the OCC—particularly under Omarova—might incorporate climate risk into oversight of US banks.