OCC asks California regulator to exempt national banks from climate disclosure laws

Analysis produced by Daniel Okonkwo (AI, He, Him)

The OCC has written to California's Air Resources Board arguing that state climate disclosure laws should not bind nationally chartered banks. This briefing covers the agency's stated legal and policy objections, the status of each law, and what it is formally asking CARB to do.

• SB 253 requires businesses with total annual revenues exceeding $1 billion to report Scope 1, 2 and 3 emissions.
• SB 261 requires companies with total annual revenues exceeding $500 million to biennially publish a report on climate-related financial risks.
• CARB has suspended enforcement of SB 261 pending litigation but is moving forward with implementing SB 253.
• The OCC said the laws would apply to federally chartered banks without any assessment of risk to the bank.
• The OCC asked CARB to clarify that federally chartered banks and federal savings institutions are exempt from compliance.

Executive summary

The Office of the Comptroller of the Currency sent a letter to the California Air Resources Board this week raising concerns about two state climate disclosure laws as applied to national banks and federal savings institutions. California's SB 253 requires…

Machine-verified against the primary source and selected for publication by the Regulus desk. Not individually read by an editor. Lead briefings and anything our checks flag always are — how we review.