Read twice and referred to the Committee on Banking, Housing, and Urban Affairs.
The bill directs the Federal Reserve Board, working with specified federal ‘‘climate science leads,’’ to develop three climate-change financial risk scenarios and a Technical Development Group to advise on them. It requires biennial climate-related stress analyses of very large bank holding companies and designated nonbank financial companies, initial public summaries, and, after the pilot phase, mandatory climate risk resolution plans with capital policies and possible restrictions on capital distributions if plans are rejected.
Scope of Fed authority: necessary financial stability tool vs federal overreach
Relative to its intended legislative type, this bill is a substantive regulatory change that is well-integrated into existing supervisory law and provides substantial procedural scaffolding (scenario definitions, advisory group, timelines, reporting).
The bill directs the Federal Reserve Board, working with specified federal ‘‘climate science leads,’’ to develop three climate-change financial risk scenarios and a Technical Development Group to advise on them.
It requires biennial climate-related stress analyses of very large bank holding companies and designated nonbank financial companies, initial public summaries, and, after the pilot phase, mandatory climate risk resolution plans with capital policies and possible restrictions on capital distributions if plans are rejected.
The Fed must also survey supervised firms with at least $10 billion in assets about exposure and adaptation plans, and publish aggregate reports periodically.
Technically detailed and narrow but politically sensitive; imposes new prudential requirements on powerful financial actors, so passage faces notable resistance.
Relative to its intended legislative type, this bill is a substantive regulatory change that is well-integrated into existing supervisory law and provides substantial procedural scaffolding (scenario definitions, advisory group, timelines, reporting). It leaves significant methodological and resource details to the Board and agency partners and omits explicit fiscal authorizations and some accountability mechanisms.
Scope of Fed authority: necessary financial stability tool vs federal overreach
These are examples from the analysis, not a ranked list of the most-affected groups.
Scope of Fed authority: necessary financial stability tool vs federal overreach
Likely broadly supportive: views the bill as a necessary, systemic approach to climate-related financial risk, improving transparency and resilience.
Would welcome Fed-led scenario analysis and mandates that require capital planning and public reporting, while urging protections for disadvantaged communities.
Cautiously supportive: sees merit in stress-testing for systemic climate risks but wants rigorous, transparent methodologies, phased implementation, and minimized unintended economic disruption.
Will look for clear legal authority, international coordination, and cost-benefit evidence.
Likely opposed or skeptical: views the bill as an expansion of regulatory authority and politicization of the Fed’s role.
Concerns center on economic impacts, supervisory overreach, and subjective climate scenario use to penalize certain industries.
Reached or meaningfully advanced
Reached or meaningfully advanced
Still ahead
Still ahead
Still ahead
Technically detailed and narrow but politically sensitive; imposes new prudential requirements on powerful financial actors, so passage faces notable resistance.
The bill has not accumulated any surfaced votes yet.
Scope of Fed authority: necessary financial stability tool vs federal overreach
Technically detailed and narrow but politically sensitive; imposes new prudential requirements on powerful financial actors, so passage fac…
Relative to its intended legislative type, this bill is a substantive regulatory change that is well-integrated into existing supervisory law and provides substantial procedural scaffolding (scenario definitions, adviso…
Go beyond the headline summary with full stakeholder mapping, legislative design analysis, passage barriers, and lens-by-lens tradeoff breakdowns.