FMB Comments on the OSFI Draft Guideline B-15 Climate Risk Management

FMB is pleased to provide you with comments on the Office of the Superintendent of Financial Institutions (“OSFI”) proposed Draft Guideline B-15 Climate Risk Management (“the guideline”).

The guideline is an important step in setting clear guidance for the management of climate-related risks for Federally Regulated Financial Institutions (“FRFIs”). The FMB commends the work that has been done by OSFI in this emerging reporting area. The FMB supports the development of guidelines around the disclosure of climate-related risks as well as greenhouse gas (“GHG”) emissions. However, the proposed guidance has failed to consider the United Nations Declaration on the Rights of Indigenous People (“UNDRIP”) and the Final Report of the Truth and Reconciliation Commission (“TRC”) of Canada.

FMB Comments on Draft Guideline B-15 Climate Risk Management

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