August 11, 2022

The Honorable Jerome H. Powell ChairmanBoard of Governors of the FederalReserve System 20th Street andConstitution Avenue, NW Washington, DC 20551 Mr. Michael Hsu Acting ComptrollerOffice of the Comptroller of theCurrency400 7th Street, SWWashington, DC 20219 The Honorable Sandra Thompson DirectorFederal Housing Finance Agency400 7th Street, SWWashington, DC 20219 The Honorable Rostin Behnam ChairmanCommodity Futures TradingCommission […]

In less than two years, the priority of the White House has shifted dramatically from the Trump Administration striving
for energy independence through domestic production to the Biden Administration striving to mitigate climate change by issuing executive orders designed to aggressively transition our nation away from fossil fuels. The shift of the political pendulum on energy policy has led federal regulatory agencies that directly govern or impact the banking industry to draft guidance documents, propose reporting requirements and initiate disclosure standards that are clearly intended to
limit and/or shift capital flowing to energy producers and energy users that produce greenhouse gas emissions. Like it or not, our industry has been pulled into the climate change debate.