海外之声 | 完善金融体系以应对气候变化的挑战
导读
气候变化和可持续发展对金融系统有很重要的意义。金融系统可以帮助企业有效管理气候变化的风险，并且抓住经济转变过程中的投资机会。
首先极端气候变化的事件发生频次逐渐提高。为此，保险公司正在逐步改变他们的承销方式，定价策略以及投资决定。同样的，沿海地区的房屋抵押贷款也经受了冲击，他们更易接受来自飓风以及海平面上升等因素的威胁，所以房屋的出借者倾向于证券化抵押贷款以减少气候变化、违约和贬值的风险。企业可以通过投资低碳创新、基础设施建设、能源、交通等来规避气候变化的风险。
其次，气候变化降低了金融市场的稳定性。因为不清楚气候变化对实体资产和金融资产的影响，重新定价这些资产变得愈发困难。同样的，投资者对于未来政策的判断也在逐步变化，导致了价格超出预期的波动。评估气候变化的影响是很困难的，因为气候变化并不是线性的，而且很有可能会有临界点存在；不仅如此，会计准则以及披露框架的不确定导致投资者无法正确估价。为此，企业需要对其面对的气候变化风险进行可持续的，可比较的并且可执行的披露，以及准确的估价。目前一种有效评估气候风险的方法是通过情景分析，可以清楚了解金融系统如何面对气候变化。
如何去测量、建模、管理银行系统中的气候变化风险，首先需要借助监管者的力量来保证所有机构有能力面对风险。尽管气候变化影响银行系统的渠道我们已经很清楚了，但是量化这些风险仍然是具有挑战性的。数据缺口以及测量困难同样导致风险升级。美联储正在建立一个新型的缩小数据差距的网络——绿色金融工作网（NGFS）。
金融机构同样可以帮助社区和个人提高应对风险的能力。根据社区再投资法案（CRA），；银行有义务稳定和振兴受到自然灾害冲击的社区。所以美联储最近首次就拟议的CRA规则制定发出预先通知，旨在寻求有关提供CRA信贷以鼓励贷款和投资以促进备灾和应对气候变化的反馈。
在未来的几年里，美国的监管机构将通力合作提升美国金融系统应对气候变化的能力，他们也将帮助企业评估和解决相关转型问题以保证私营部门充满活力。
作者 | 莱尔·布莱纳德（Lael Brainard），美联储理事会成员
英文原文如下：
Strengthening the Financial System to Meet the Challenge of Climate Change
Lael Brainard
December 18, 2020
Remarks by Lael Brainard Member of the Board of Governors of the Federal Reserve System at “The Financial System & Climate Change: A Regulatory Imperative” hosted by the Center for American Progress
I want to thank the Center for American Progress for inviting me to join you in discussing climate change and the U.S. financial system. Let me start by noting these are my own views and do not necessarily reflect those of the Federal Reserve Board or the Federal Open Market Committee.
Climate change and the transition to a sustainable economy have important implications for the financial system. The financial system can be a powerful enabler to help the private sector manage climate-related risks and invest in the transition. It is vitally important to strengthen the U.S. financial system to meet the challenge of climate change.Meeting the Challenge of Climate Change
Climate change is one of the major challenges of our time. There is growing evidence that extreme weather events related to climate change are on the risedroughts, wildfires, hurricanes, and heatwaves are all becoming more common. Climate-related events are already adversely affecting the lives of many Americans. The economic and financial impacts are also increasingly evident: we are already seeingelevated financial losses associated with an increased frequency and intensity of extreme weather events. Some have described Pacific Gas and Electric’s bankruptcy as the first climate-related bankruptcy of a major U.S. corporation.
Average annual insured weather-related catastrophe losses have increased over the past decade. With losses increasing, insurers are incorporating the impact of climate change into their underwriting assumptions, pricing, and investment decisions. Climate change is also likely to have a notable impact on coverage availability. Some insurers have discontinued policies in fire-prone areas, which, in turn, is changing the costs of homeownership and the risk profiles of previously underwritten mortgages.
Similarly, mortgages in coastal areas are vulnerable to hurricanes and sea level rise. New mortgages issued for U.S. coastal homes have, in aggregate, exceeded $60 billion annually in recent years. Recent research suggests that lenders hit by hurricanes, particularly in areas not typically affected by natural disasters, tend subsequently to securitize more of their mortgage loans, which could have higher climate risks, higherborrower defaults, and lower collateral values. Homeowners could also face increased hardship, since many homeowner insurance policies exclude flooding.
Just as there are risks, there are also promising opportunities for private-sector investments in low-carbon innovation, infrastructure, energy, and transportation. With support from accounting standard setters, credit rating agencies, and regulators, the financial system can provide useful signals to help the private sector manage climate risks and facilitate a smooth transition.Climate Risks and Financial Stability
Climate change could pose important risks to financial stability. That is true for both physical and transition risks. A lack of clarity about true exposures to specific climate risks for physical and financial assets, coupled with uncertainty about the size and timing of these risks, creates vulnerabilities to abrupt repricing events. For example, a shift in the perceived frequency or severity of climate-related events, such as storms, floods, or wildfires, could rapidly change perceptions of risk and lead to rapid repricingof assets. Similarly, changes in investor expectations about future climate policies could lead to rapid and unexpected price changes that ripple through the financial system.
Assessing climate risk effects is complex because the predicted path of climate change is nonlinear and has likely tipping points, beyond which changes in climate conditions could occur rapidly, and climate forecasts based on historical data are no longer relevant. This uncertainty in climate forecasts may reduce the accuracy of risk models used by investors, risk managers, asset managers, financial infrastructures, and leveraged financial institutions.
With accounting standards and disclosure frameworks for climate risk in the early stages of development and adoption, investors may lack transparency around the range of climate-related exposures facing financial firms, and non-financial short-term investors may be disinclined to fully price in longer-term climate effects. Some studies suggestthat even well-informed investors may underestimate the likelihood of large shocks related to climate. Combined with the uncertainty in the timing and magnitude of climate change itself, this mispricing could lead to financial volatility as conditions evolve and perceptions shift.
Consistent, comparable, and actionable disclosures are critical to understanding firms’ exposures to climate risks and to accurately pricing that risk. The Task Force on Climate-Related Financial Disclosures (TCFD), a private sector-led initiative with support from the Financial Stability Board, provides a consistent global framework for companies and other organizations to improve standardization of climate-related financial disclosures. As of October 2020, nearly 1,500 organizations with a combined market capitalization of $12.6 trillion, including financial institutions that own or manage assets of $150 trillion, had expressed their support for the TCFD framework. This support signifies strong demand from the private sector and investors for greater transparency around climate-related risks to better inform decisionmaking.
We are improving our understanding of climate risks and their impact on financial stability through staff research and engagement with other central banks on topics like climate scenario analysis. One useful approach to assessing the effect of climate-related risks is through scenario analysis of how the financial system is exposed and how it may respond to climate-related risks. Climate scenario analysis identifies climate-relatedphysical and transition risk factors facing financial firms, formulates appropriate stresses of those risk factors under different scenarios, and measures their effects on individual firms and the financial system as a whole. In part because of the different nature of climate-related risks relative to financial and economic downturns and the significantly longer planning horizon, this is distinct from established regulatory stress tests at banks, which are used to assess capital adequacy over a relatively short horizon.Measuring, Modelling, and Managing Climate Risk in the Banking System
Supervisors are responsible for ensuring that supervised institutions are resilient to all material risks, including those associated with climate change. The economic and financial market consequences of climate change and the accompanying economic transition will have direct implications for bank balance sheets, strategies, and operations, and could increase credit, market, liquidity, or operational risk at banks. These climaterelated developments may affect the creditworthiness of corporate, household, and government borrowers. Climate-related risks may reduce a borrower’s repaymentcapacity or the value of assets collateralizing a loan, exposing banking institutions to losses. Similarly, climate-related risks may impact the level and volatility of asset prices, thus affecting the value of a bank’s portfolios. Severe weather events may disrupt a bank’s data centers or operations and impede its ability to provide financial services to customers.
Although the transmission channels through which climate risks affect banks are increasingly apparent, quantification of those risks remains challenging. To date, measurement efforts have been hampered by data gaps and methodological hurdles, many of which are unique to climate change and contribute to elevated uncertainty in estimates of climate-related risks. For instance, assessment of the potential impact of climate change on a bank may require precise data on the geolocation of a counterparty’s assets and operations, as well as information on local weather patterns for those locations. It may also require knowledge of a counterparty’s carbon emissions and of policies in different industries and jurisdictions. Data at this level of granularity are often unavailable or extremely difficult to acquire, presenting challenges in calculating the magnitude of climate-related financial risks. Two-thirds of respondents to a recent survey of members of the Basel Committee on Banking Supervision’s Task Force on Climate-Related Financial Risks (TFCR) indicated that they lack sufficiently granular or reliable data necessary to run climate risk assessment models.Filling these data gaps is critical for measuring the banking sector’s exposure to climate risk and analyzing the implications for financial stability and prudential risks. Federal Reserve staff are participating in a new Network for Greening the Financial System (NGFS) workstream on “Bridging the Data Gaps.” The workstream will create a detailed list of gaps in data items at the macroeconomic level, the market level, and the financial market participant level needed to model climate risk.
Climate change also poses distinct modelling challenges. The several decades over which climate risks are projected to materialize far exceed a bank’s typical risk management and planning time horizon. Moreover, financial risk models are often backward-looking and extrapolate historical trends, which, in the case of climate, may be unreliable predicators of future outcomes. New tools and forward-looking approaches will be required.
We continue to strengthen our understanding of how banks are measuring and managing climate risks. Over time, it will be important to develop a framework for evaluating how banks are taking into account climate-related risk in their modelling and management of credit, market, liquidity, and operational risks. Some jurisdictions have developed programs to provide banks with supervisory expectations to manage their risks associated with climate change. As a financial industry association has noted, “Climaterisk analysis and measurement is—rightly—rising quickly on both the industry and regulatory agenda. Both regulators and firms want to better understand risk profiles to ensure effective management of transition and physical risks as well as potential adequacy of financial resources.”
We benefit from continued engagement both domestically and internationally with colleagues from other regulatory agencies, supervisory authorities, and international standard setting bodies. For instance, the Federal Reserve co-chairs the Basel Committee on Banking Supervision’s TFCR. The TFCR is mapping the transmission channels and studying the measurement methodologies of climate-related financial risks to the banking system. It will also examine the extent to which climate-related financial risks are incorporated in the existing Basel Framework. Based on this analysis, the TFCR is charged with and is developing recommendations for effective supervisory practices to mitigate climate-related financial risks.Climate Change and Community Reinvestment
Financial institutions can also help communities and individuals build greater resilience to climate risk. Recent research highlights the significant ways in which lowerincome households and underserved areas are affected by natural disasters and climate risk. Lower-income households with low levels of liquid savings tend to be less resilient to the temporary loss of income, property damage, displacement costs, and health challenges they face from disasters. In addition, low- and moderate-income (LMI) communities are often located in areas that are particularly vulnerable to climaterelated risks, have greater health-related impacts due to climate change, or have housing that is more susceptible to disaster-related damage.
Under the Community Reinvestment Act (CRA), banks have an affirmative obligation to meet the needs of their local communities, including LMI communities. Existing CRA regulations allow banks to receive CRA credit for activities to revitalizeand stabilize communities after a natural disaster has occurred in certain federally designated disaster areas. For natural disasters that have caused widespread devastation and economic impact, such as Hurricanes Katrina and Maria, the Board has worked with other banking regulators to provide CRA consideration for bank investments in stabilization and revitalization outside of a bank’s assessment area or regional area.
It is important to LMI communities and other underserved communities to be proactive in working to equitably mitigate the risks of climate change in advance. Reflecting this, the Federal Reserve’s recent advance notice of proposed rulemaking on the CRA for the first time seeks feedback on providing CRA credit to encourage loans and investments that promote disaster preparedness and climate resilience. We want to encourage lenders to invest and rebuild in ways that will increase resilience to future climate risks in underserved and local LMI communities. We look forward to receiving comment on our questions regarding disaster preparedness and climate resilience by the February 16, 2021, deadline.Looking Ahead
A year ago, I laid out some of the important areas where climate change matters for the Federal Reserve’s statutory responsibilities. The Federal Reserve has been making important progress in laying the groundwork to incorporate climate considerations where they are material and relevant to our statutory responsibilities, today and in the future. Across the Federal Reserve System, we have sought to deepen our understanding of the implications of climate change for the U.S. economy and financial system, including through the Virtual Seminar on Climate Economics series, internal groups focused on the emerging climate literature, and academic conferences at several Federal Reserve Banks. Federal Reserve staff are collaborating and sharing knowledge through our System Climate Network and other forums. We have recruited economists with expertise in climate-related topics and obtained a variety of climate-related data resources.Last month, the Federal Reserve Financial Stability Report incorporated for the first time an analysis of the ways climate change could present risks to financial stability. Similarly, the Federal Reserve Supervision and Regulation Report described how climate-related risks can create microprudential risks and how supervisors are working to better understand, measure, and mitigate these risks. Last quarter, the Federal Reserve released a CRA proposal that for the first time highlighted the importance of investing in climate resilience for LMI and underserved communities.
Building on this foundation, this week the Federal Reserve Board became a full member of the NGFS. We look forward to learning from and collaborating with foreign central banks on addressing data gaps and undertaking research on the implications of climate change for financial stability and the economy.
In the years ahead, there will be significant opportunities for collaboration across the U.S. regulatory agencies in strengthening the U.S. financial system to meet the challenge of climate change. Together, these efforts can help equip the deepest financial market in the world to support our dynamic private sector in assessing and addressing climate-related risks and investing in the transition.
编译 杨沁容
编辑 查王皓天
来源 BIS
责编 李锦璇、蒋旭
监制 朱霜霜
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