Climate Risk Range of Practice

Forms and Documents

Document Name	Status
Questionnaire Form	New
Climate Change ROP Emergency Request Letter.pdf Supplementary Document	2021-11-01
PRA Emergency Request Supporting Statement - Climate Risk ROP.docx Supporting Statement A	2021-10-29

IC Document Collections

IC ID	Document Title	Status
249982	Questionnaire Form	New

ICR Details

OMB Control No:	ICR Reference No: 202110-1557-005
Status: Received in OIRA	Previous ICR Reference No:
Agency/Subagency: TREAS/OCC	Agency Tracking No:
Title: Climate Risk Range of Practice
Type of Information Collection: New collection (Request for a new OMB Control Number)	Common Form ICR:  No
Type of Review Request: Emergency	Approval Requested By: 11/01/2021
Date Submitted to OIRA: 11/01/2021

	Requested	Previously Approved
Expiration Date	6 Months From Approved
Responses	20	0
Time Burden (Hours)	3,400	0
Cost Burden (Dollars)	0	0

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Abstract: The OCC is planning to conduct a climate risk range of practice among large banks with the purpose of developing an understanding of climate risk management practices as it pertains to climate-related financial risk. Climate risks can have a material impact on the financial system by damaging property, impeding business activity, shifting the values of assets, and affecting incomes. Banks are exposed to both physical risks and transition risks presented by climate change which may impact the safety and soundness of supervised institutions. Given the potential significance of these risks, the OCC is requesting emergency clearance for this range of practice to assist with understanding banks’ current and planned approaches to climate-related financial risks and whether any supervisory clarifications or enhancements are warranted. The OCC is planning to collect the information through the range of practice to understand the financial risks and ensure the establishment of sound risk management frameworks to measure, monitor, and control risks presented by climate change. The agency understands that some banks are working to incorporate climate-related financial risks into their existing risk management frameworks and business strategies. The OCC recognizes that banks’ exposure to climate-related financial risks and their climate risk management practices may vary substantially based on institutions’ size, complexity of operations, geographic footprint, business model, and risk profile. The range of practice will not result in an adequacy assessment as to the banks’ current climate risk management program. The range of practice will • inform the need for clarification or development of necessary supervisory expectations • start to establish baseline supervisory knowledge • help identify challenges and gaps in risk management frameworks • inform the agency on plans to evolve current practices

Emergency Justfication: The recent FSOC report on climate risk highlighted the financial stability implications of climate risk. The report also discussed a wide variety of challenges and data gaps present. This range of practice request will help the OCC better assess these challenges and gaps which is why the agency is requesting the emergency authorization.

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Authorizing Statute(s): None

Citations for New Statutory Requirements: None

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Associated Rulemaking Information
RIN:	Stage of Rulemaking:	Federal Register Citation:	Date:
	Not associated with rulemaking

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Federal Register Notices & Comments

Did the Agency receive public comments on this ICR? No

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Number of Information Collection (IC) in this ICR: 1

IC Title	Form No.	Form Name
Questionnaire	N/A	OCC Climate Risk Questionnaire

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ICR Summary of Burden

	Total Request	Previously Approved	Change Due to New Statute	Change Due to Agency Discretion	Change Due to Adjustment in Estimate	Change Due to Potential Violation of the PRA
Annual Number of Responses	20	0	0	20	0	0
Annual Time Burden (Hours)	3,400	0	0	3,400	0	0
Annual Cost Burden (Dollars)	0	0	0	0	0	0

Burden increases because of Program Change due to Agency Discretion: Yes

Burden Increase Due to: Miscellaneous Actions

Burden decreases because of Program Change due to Agency Discretion: No

Burden Reduction Due to:

Short Statement: The increase in burden is due to the fact that this is a new collection.

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Annual Cost to Federal Government:

Does this IC contain surveys, censuses, or employ statistical methods? No

Does this ICR request any personally identifiable information (see OMB Circular No. A-130 for an explanation of this term)? Please consult with your agency's privacy program when making this determination.     No

Does this ICR include a form that requires a Privacy Act Statement (see 5 U.S.C. §552a(e)(3))? Please consult with your agency's privacy program when making this determination.     No

Is this ICR related to the Affordable Care Act [Pub. L. 111-148 & 111-152]? No

Is this ICR related to the Dodd-Frank Wall Street Reform and Consumer Protection Act, [Pub. L. 111-203]? No

Is this ICR related to the American Recovery and Reinvestment Act of 2009 (ARRA)? No

Is this ICR related to the Pandemic Response? No

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Common Form ICR:  No

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On behalf of this Federal agency, I certify that the collection of information encompassed by this request complies with 5 CFR 1320.9 and the related provisions of 5 CFR 1320.8(b)(3).

The following is a summary of the topics, regarding the proposed collection of information, that the certification covers:

(a) It is necessary for the proper performance of agency functions;

(b) It avoids unnecessary duplication;

(c) It reduces burden on small entities;

(d) It uses plain, coherent, and unambiguous language that is understandable to respondents;

(e) Its implementation will be consistent and compatible with current reporting and recordkeeping practices;

(f) It indicates the retention periods for recordkeeping requirements;

(g) It informs respondents of the information called for under 5 CFR 1320.8 (b)(3) about:

(i) Why the information is being collected;

(ii) Use of information;

(iii) Burden estimate;

(iv) Nature of response (voluntary, required for a benefit, or mandatory);

(v) Nature and extent of confidentiality; and

(vi) Need to display currently valid OMB control number;

(h) It was developed by an office that has planned and allocated resources for the efficient and effective management and use of the information to be collected.

(i) It uses effective and efficient statistical survey methodology (if applicable); and

(j) It makes appropriate use of information technology.

If you are unable to certify compliance with any of these provisions, identify the item by leaving the box unchecked and explain the reason in the Supporting Statement.

Certification Date: 11/01/2021

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