September 29, 2022
Submission to Office of the Superintendent of Financial Institutions (OSFI) for its draft Guideline B-15 Climate Risk Management
The Canada Climate Law Initiative (CCLI) applauds the Office of the Superintendent of Financial Institutions (OSFI) for its draft Guideline B-15 Climate Risk Management. The proposed Guideline is important recognition that climate-related risks can significantly affect the safety and soundness of federally-regulated financial institutions (FRFI), in turn affecting the integrity of the Canadian financial system. The proposed Guideline marks the first time in Canada that regulatory authorities are adopting a leadership role in respect of management of climate-related risks in the financial sector and the need to build resilience in the transition to a decarbonized economy. The CCLI strongly supports the work of OSFI and the vast majority of the content of the proposed guideline. That said, the CCLI has five recommendations that we believe are particularly important in enhancing it further.