Trickle-down climate risk regulation.

Abstract

Climate change impacts-including flooding, wildfires, and crop failures-are destroying ecosystems, homes, infrastructure, farms, and businesses. Regulators around the globe are paying increasing attention to what these events mean for banks and the financial system, with several attending not only to bank impacts from, but also bank contributions to, climate change. The European Central Bank, for example, is signaling to banks that they must plan and make their transition away from financing of fossil fuels-to respond not only to their own risks but also to the science pointing to the necessity of this transition for the planet and financial system. Yet in the US, the primary regulators of national and community banks are narrowly zeroing in on risks posed to the largest banks-those with over $100 billion in total consolidated assets-without attention to these banks' role in financing greenhouse gas-emitting activities and what they mean for other important financial actors. Such a "trickle-down" approach to regulation-assuming that protecting big banks will protect other, smaller financial entities and the financial system more broadly-obscures the financial crisis that is already underway and inadequately responds to scientific evidence on distinctive features of climate risk and impacts.