Letter to CARB on Climate-Disclosure Legislation

To The CARB:

The American Bankers Association appreciates the opportunity to comment on the Information Solicitation to Inform Implementation of California Climate-Disclosure Legislation: Senate Bills 253 and 261, as amended by SB 219 ("The Solicitation"). The Solicitation asks for recommendations and discussion of key aspects of the laws enacted through SB 253 and 261 (the laws) to allow CARB to assess the scope, nature, extent, and timing of reporting under the laws, as well as considerations related to the measurement and assurance related to reporting of greenhouse gas emissions metrics (GHGs) under SB 253.

This letter provides a high-level overview of some of the challenges financial institutions face in climate-related disclosures and the practical recommendations we believe are important for CARB's implementation of SB 253 and SB 261. ABA members consist of a wide range of lending institutions of all sizes and business models. In addition to the large banks that have implemented aspects of climate and GHG reporting through voluntary reports, dozens of mid-sized and community banks in the U.S. are likely to be required to file reports to CARB under the laws. Due to specific definitions within Scope 3 of the Greenhouse Gas Protocol related to financed emissions, however, our recommendations will apply not only to the compliance of banks to submit their respective reports to CARB under SB 253, but potentially also to the many companies in which banks invest in or do business with.

Below, we summarize our key recommendations, which we cover in greater detail in the attached Appendix to the letter.

Download the letter to read the full text.