Climate and Environment

Today the Revolving Door Project released a report on the Office of Financial Research’s (OFR) capacity to proactively investigate and inform climate-aware regulation across the federal financial regulatory landscape. This is the fourth installment of our Climate Finance Capacity project, which examines the current state of financial regulation through the lens of the climate crisis. Our prior installments have looked at the role and capacity of the Commodities Future Trading Commission (CFTC), the Securities and Exchange Commission, and the Office of the Comptroller of the Currency (OCC) in crafting a more sustainable financial future. 

The Office of Financial Research (OFR) was established by the Dodd-Frank Wall Street Reform and Consumer Protection Act in 2010. Charged with providing data, analysis, and research regarding systemic financial risks to the members of the Financial Stability Oversight Council (FSOC), OFR is an integral part of the federal infrastructure for safeguarding financial stability. OFR, while not itself a regulatory body, investigates systemic risks, standardizes the data used across government, and can offer financial regulators a more robust empirical base from which to devise regulations. OFR was designed to address the proven inability of financial regulators in the lead up to the Great Recession to understand dangers before threats turned into devastation.

Addressing the climate crisis on a federal level requires, at minimum, that the agencies and departments of the federal government be fully staffed and equipped to implement and enforce regulations. In the Revolving Door Project’s Climate Capacity Crisis Report, we initially found that the Department of Energy (DOE) had relatively higher staffing levels compared to other agencies, though certainly not enough to fulfill its mandate. As of June 2021, Biden’s DOE had hired 79 more STEM employees than were employed by the department in September 2016, whereas the Department of Agriculture, Department of Interior, National Park Service, United States Geological Survey, and the Environmental Protection Agency all lost STEM employees within that same time period. Despite the DOE’s comparably impressive staffing levels, a recent Washington Post article revealed that the department was struggling to stay on top of mounting work, causing unnecessary problems in their fight against the climate crisis.

President Biden nominated Tommy Beaudreau to be his Deputy Secretary of the Department of the Interior last April, and he was confirmed to the position by June. Unfortunately, though Biden seeks to be seen as a climate champion, Beaudreau was, and is, a uniquely terrible choice to help helm a climate-focused administration. His revolving door record is extensive, his conflicts of interest are nearly unprecedented, and his (re)installment at the highest circles of the Department of the Interior was ultimately a win for oil and gas conglomerates. 

supervising all national banks, federal savings associations, and agencies of foreign banks. It primarily regulates the risk that banks can take on, delineates what is considered “banking,” and investigates banks’ balance sheets. 

Today the Revolving Door Project released a report on the Office of the Comptroller of the Currency’s OCC) capacity to implement and enforce climate regulation. This is the third installment of the project’s ongoing Climate Finance Capacity project \identifying the tools each component of the Financial Stability Oversight Council (FSOC) has to address the climate crisis through regulatory reform and the capacity-related obstacles that could stand in the way. Prior installments have looked at the Commodities Future Trading Commission (CFTC) and the Securities and Exchange Commission (SEC).Through this project, we aim to highlight the responsibility each of these agencies have in regulating our financial system towards a more sustainable future, and the reforms necessary to achieve this vision as examined through the lens of each agency’s unique resourcing.

Climate change poses a serious threat to everything the Securities and Exchange Commission (SEC) is meant to protect and oversee. The Commodity Futures Trading Commission (CTFC)’s “Managing Climate Risk in the U.S. The Financial System ”report makes this abundantly clear. The report concludes that climate change may “exacerbate existing, non-climate related vulnerabilities in the financial system, with potentially serious consequences for market stability”. Furthermore, the physical and transitional risks of climate change will likely lead to systemic and sub-systemic financial shocks. These shocks would cause “unprecedented disruption in the proper functioning of financial markets and institutions” and further marginalize communities underserved by the financial system. To fulfill its mandate, of maintaining fair, orderly, and efficient markets, protecting investors, and facilitating capital formation, the SEC must proactively ensure there is enough personnel to monitor and enforce regulations that will keep markets stable and adaptable. 

Today, the Revolving Door Project released its SEC Climate Capacity Report examining the detrimental impact of capacity shortfalls on the Securities and Exchange Commission (SEC)’s climate work. This report is the second installment of its Climate Finance Capacity Project. The Climate Finance Capacity Project explores the power and responsibility that each of the Financial Stability Oversight Council’s member agencies has to address the climate crisis and consider how resource limitations threaten to limit their impact. 

The president has the power to reform the wayward Tennessee Valley Authority. It’s a bigger deal than you think.

When the government’s lawyers defend fossil fuel interests, people and the planet pay the price.

The Biden Administration was elected to office with an urgent mandate to change our current trajectory towards catastrophic climate change. Climate-focused financial regulation, or the regulation of markets to accurately account for climate risk and the social and material costs of climate-damaging activities, must be a part of this coordinated federal response in order to meaningfully address climate concerns at the governmental level. An agency that is particularly key to this goal is the Commodity Futures Trading Commission (CFTC). The CFTC is one of the smallest federal financial regulatory bodies and yet it is responsible for regulating one of the country’s largest markets, derivatives. While it was originally founded to regulate futures trading in commodities, the passage of the Dodd-Frank Wall Street Reform and Consumer Protection Act in 2010 expanded the CFTC’s mandate to include swaps markets and broadened the agency’s role in regulating other derivatives, in part due to their extreme volatility and outsized role in the 2008 financial crisis. 

President Biden signed the elusive bipartisan infrastructure bill into law on November 15th. It’s just the first part of a planned two-part infrastructure push, the other being the Democrat-only Build Back Better Act which Joe Manchin and Kyrsten Sinema have slashed to pieces. Yet Biden keeps calling the bipartisan bill he signed a climate bill. 

“We are extremely disappointed to see Biden renominate Jerome Powell as Chair of the Federal Reserve Board. Biden’s endorsement of Powell’s deregulatory agenda will greatly harm American families. Biden has an ambitious and urgent agenda on climate, financial stability, and addressing racial and economic inequality. Powell as Chair of the Federal Reserve will make it more difficult for Biden to ultimately be a successful president. Today is a win for the conventional wisdom and Establishment and a defeat for the planet and Joe Biden’s ultimate legacy.”

Congressional selfies and self-congratulations inaugurated the week, but a lot of hard work remains to translate the Infrastructure Investment and Jobs Act’s (IIJA) policies into real-life results. Given that those policies are (generously) middling and that the most promising ones are underfunded, turning these into winning programs will demand energy, creativity, competence, and a strong commitment to the public interest.