On November 8, 2021, the acting head of the Office of the Comptroller of the Currency (OCC), Michael J. Hsu, issued a call to action on climate change to the boards of directors of OCC-regulated banks. Specifically, he outlined an initial series of climate change-related questions that boards should be asking bank management and stated that bank boards should use the exercise to help improve climate risk management practices and build up climate risk management and reporting capabilities. While he indicated that this is a long-term effort that will include further guidance from the agency, it is clear from his call to action that the OCC expects banks to begin right now. In this Legal Update, we explain the background to the OCC’s risk management initiatives and discuss this recent call to action on climate risk.

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