Submitted electronically via https://comments.cftc.gov

October 7, 2022

Christopher Kirkpatrick
Secretary
Commodity Futures Trading Commission
Three Lafayette Centre
1155 21st Street NW
Washington, DC 20581

Re: Climate-Related Financial Risk RFI

Dear Mr. Kirkpatrick:

The Securities Industry and Financial Markets Association (“SIFMA”), the Asset Management Group of SIFMA (“SIFMA AMG”), and the Institute of International Bankers (the “IIB”)1 appreciate the opportunity to comment on the Commodity Futures Trading Commission’s (the “Commission”) request for information2 regarding climate-related financial risk (the “RFI”). We support the Commission’s efforts to better inform its understanding and oversight of climate-related financial risk where pertinent to the derivatives markets and appreciate the opportunity to submit our comments in response to the RFI.

Our members are at the forefront of (1) working to develop risk management frameworks to manage climate-related financial risks and (2) developing products and services to hedge risk related to climate risk factors and contribute to market efficiency and resiliency with respect to climate-related financial risks. We look forward to working with the Commission and other regulators to address the recommendations set forth in the Financial Stability Oversight Council’s (“FSOC”) Climate-Related Financial Risk Report (“FSOC Report”) that relate to the derivatives markets.

1 Please see the Appendix for more information on SIFMA, SIFMA AMG, and IIB.

2 See Request for Information on Climate-Related Financial Risk, 87 Fed. Reg. 34856 (proposed June 8, 2022), available at https://www.cftc.gov/sites/default/files/2022/06/2022-12302a.pdf.