April 5, 2023

VIA ELECTRONIC SUBMISSION

Adrienne Harris, Superintendent
New York State Department of Financial Services
1 State Street
New York, NY 10004-1511

Re: Proposed Guidance for New York State Regulated Banking and Mortgage Organizations Relating to Management of Material Financial Risks from Climate Change

Dear Superintendent Harris:

The Institute of International Bankers (the “IIB”)1 and the Securities Industry and Financial Markets Association (“SIFMA”)2 appreciate the opportunity to submit this letter in response to the request for feedback issued by the New York State Department of Financial Services (the “NYDFS”) on its Proposed Guidance for New York State Regulated Banking and Mortgage Organizations Relating to Management of Material Financial Risks from Climate Change (the “Proposal”).3 The management of climate-related financial risk is an important issue, and one that is particularly significant for our members. As such, we welcome the opportunity to offer our perspectives.

Our members recognize the global significance and importance of addressing climate-related financial risk. Many of our members are already in the process of incorporating climate-related risk drivers into their existing risk management frameworks at the enterprise level, across multiple jurisdictions. As such, we applaud the efforts of the NYDFS to coordinate with other domestic and international prudential regulators on climate-related financial supervision and appreciate that the Proposal is broadly compatible with other domestic and international climate-related financial risk management guidance.

1 The IIB represents internationally headquartered financial institutions from over 35 countries around the world doing business in the United States. The IIB’s members consist principally of international banks that operate branches, agencies, bank subsidiaries, and broker-dealer subsidiaries in the United States.

2 SIFMA is the leading trade association for broker-dealers, investment banks, and asset managers operating in the U.S. and global capital markets. On behalf of its industry’s nearly one million employees, SIFMA advocates on legislation, regulation, and business policy affecting retail and institutional investors, equity and fixed income markets, and related products and services.

3 New York State Department of Financial Services, Proposed Guidance for New York State Regulated Banking and Mortgage Organizations Relating to Management of Material Financial Risks from Climate Change (Dec. 21, 2022), available here.