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FHFA : Incorporating Climate-Related Risks into Governance ...
Published: 4/22/2024
https://www.fhfa.gov//Media/Blog/Pages/Incorporating-Climate-Related-Risks-into-Governance.aspx
Following FHFA’s Conservatorship Scorecard guidance, Fannie Mae and Freddie Mac have made progress on developing foundational climate risk frameworks, integrating climate risk considerations into their strategic planning, incorporating climate risk considerations into their management and board reporting structures, and developing educational resources for their workforce. The Federal Home Loan Banks are continuing to individually develop their decision-making processes and governance structures in consideration of climate change.
Background
In October 2021, the Financial Stability Oversight Council (FSOC) released a report1 identifying climate change as an emerging and increasing threat to financial stability. Several international organizations and standard-setting bodies have recently developed frameworks to understand, assess, and manage climate-related risks to the entities or markets within their statutory jurisdictions. These include frameworks established by the Task Force on Climate-Related Financial Disclosures,2 Bank for International Settlements (BIS),3 and U.S. regulators (Office of the Comptroller of the Currency, Board of Governors of the Federal Reserve System, and Federal Deposit Insurance Corporation),4 as well as guidance5 and hypothetical scenarios6 developed by the Network for Greening the Financial System (NGFS).7
Federal Housing Finance Agency (FHFA)
FHFA, the conservator and regulator of Fannie Mae and Freddie Mac, and regulator of the Federal Home Loan Banks (collectively, the regulated entities), recognizes the emerging and increasing threat to all stakeholders in the housing system due to climate risk and the increased frequency and intensity of major natural disasters. Strong governance is foundational to managing an institution’s risk profile, particularly when the institution must address a constantly evolving landscape of risks. Accordingly, FHFA included the need to identify ways to incorporate climate change into regulated entity governance in its 2022-2026 Strategic Plan.8 Since 2022, FHFA has established goals for Fannie Mae and Freddie Mac (the Enterprises) to develop company-wide frameworks that incorporate climate risk into existing governance and risk management structures and decision-making, and to incorporate both short- and long-term strategies into the Enterprises’ strategic planning processes.
FHFA established an internal Climate Change and ESG9 Governance Working Group (Working Group) to evaluate the integration of climate risk into the corporate governance, risk management, and strategic planning structures of the regulated entities, and incorporation into operational and business decision-making. The Working Group meets regularly with the Enterprises and evaluates their progress through the annual Conservatorship Scorecard process, reviewing the establishment of foundational governance structures, decision-making processes, and risk management practices around climate risk. The Working Group also reviews progress made by the Federal Home Loan Banks in these areas.
Enterprises
Since 2022, the Enterprises have made distinct progress towards these goals and have been focused on: developing foundational climate risk frameworks, integrating climate risk considerations into strategic planning, incorporating climate risk considerations into management and board reporting structures, and establishing training and educational resources for their workforce.
Developing ?Climate Risk Frameworks
The Enterprises have developed initial climate risk frameworks that are incorporated in their enterprise risk management frameworks in consideration of the impact that climate change could have on the achievement of their mission, strategy, and business objectives.
The Enterprises continue to make progress and develop their capacity to measure the effects of climate risks and integrate climate-related risks into risk management structures:
Freddie Mac has developed climate scenario methodologies to better quantify the impact of climate events on housing affordability, property values, and credit risk;
Fannie Mae is working on finalizing climate scenario design and methodology for intended reporting in 2024; and
Both Ent?erprises completed exploratory climate scenario analysis exercises on flood risk in 2023.
Strategic Plan Integration
To assess and address climate-related risks and opportunities that could affect their businesses, the Enterprises have been incorporating climate issues into their corporate strategic plans and planning processes.
Each Enterprise has completed ESG materiality assessments that inform their ESG and climate strategic planning processes.
Fannie Mae’s 2023-2025 Strategic Plan includes climate risk management and supporting the housing ecosystem’s adaptation to climate change as priorities.10
Board and Management-level Reporting
Fannie Mae
The board Risk Policy and Capital Committee has primary oversight of climate-related risks.
The board Audit Committee provides oversight of ESG-related reporting, which includes climate risk.
The board Community Responsibility and Sustainability Committee oversees the development and implementation of Fannie Mae’s climate risk strategy.
There is a newly established Climate Risk Committee at the management level, and Fannie Mae has designated senior executive officers to oversee climate and ESG.
Freddie Mac
The board Risk Committee has primary oversight of climate related risks.
The board Audit Committee provides oversight of ESG-related reporting, which includes climate risk.
The board Mission and Housing Sustainability Committee provides oversight responsibilities for the development, planning, implementation, performance, and execution of Freddie Mac’s mission strategies and significant initiatives, including the review of sustainability initiatives with climate change implications or impacts.
Freddie Mac has also established several advisory and steering committees at the management level for ESG and climate risk reporting.
Training and Education
Over the last few years, the Enterprises have begun educating staff on the potential impacts of climate-related risks, taking into consideration the interconnectedness and multi-dimensional nature of climate-related topics that could reach all aspects of the organization.
Federal Home Loan Banks
The Federal Home Loan Banks also continue to develop their decision-making processes and governance structures in consideration of climate change. In June 2023, the Federal Home Loan Banks released an inaugural Corporate Social Responsibility Report11 highlighting governance and risk management as foundational to their ability to meet the needs of their members and districts.
FHLBank Mission and Foundational Principles
?
?Individually, each Federal Home Loan Bank is addressing climate-related risks in accordance with its own governance and management structures. For example, the Federal Home Loan Bank of Dallas’s 2022 ESG Report12?? highlights the formation of an ESG Committee providing oversight of the FHLBank’s ESG activities. The committee assists the executive management team and board with setting ESG strategy and reviewing reports and recommendations from subcommittees, including the Climate Risk Subcommittee. At the Federal Home Loan Bank of New York, “Climate and Natural Disaster” risks have been included into the scope of the board’s Risk Committee charter.
Summary
The work undertaken by the Enterprises and Federal Home Loan Banks in managing climate risks continues to be iterative and ongoing. For 2024, FHFA established priorities for the Enterprises in the Conservatorship Scorecard related to climate risks. For the governance area, this includes strengthening risk management capabilities in identifying, assessing, controlling, monitoring, and reporting on climate risk and incorporating these capabilities into the Enterprises’ overall risk frameworks.
Responsibilities of the FHFA Climate Change and ESG Governance Working Group:
Evaluate the integration of climate risk into the corporate governance, risk management, and strategic planning structures of the regulated entities, and incorporation into operational and business decision-making.
Monitor the development and maturation of the regulated entities’ climate risk frameworks and strategic planning processes.
??
Readers are encouraged to explore the FHFA Climate Change & ESG homepage for additional blogs and information related to climate risk.
1 Financial Stability Oversight Council, Report on Climate-Related Financial Risk, 2021, https://home.treasury.gov/system/files/261/FSOC-Climate-Report.pdf.
2 The Financial Stability Board, established to coordinate at the international level the work of national financial authorities and international standard-setting bodies in order to develop and promote the implementation of effective regulatory, supervisory and other financial sector policies, created the Task Force on Climate-Related Financial Disclosures in 2015 to improve and increase reporting of climate-related financial information.
3 The Bank for International Settlements is an international consortium of central banks and monetary authorities whose mission is to support central banks' pursuit of monetary and financial stability through international cooperation, and to act as a bank for central banks. See https://www.bis.org/about/index.htm. In 2022, the Basel Committee on Banking Supervision issued principles for the effective management and supervision of climate-related financial risks. See https://www.bis.org/press/p220615.htm.
4 On October 30, 2023, the Office of the Comptroller of the Currency, Board of Governors of the Federal Reserve System, and Federal Deposit Insurance Corporation jointly issued principles that provide a high-level framework for the safe and sound management of exposures to climate-related financial risks. See https://www.federalregister.gov/documents/2023/10/30/2023-23844/principles-for-climate-related-financial-risk-management-for-large-financial-institutions.
5 See https://www.ngfs.net/en/liste-chronologique/ngfs-publications.
6 See https://www.ngfs.net/ngfs-scenarios-portal/.
7 The NGFS is a voluntary group of central banks and supervisors that work together to contribute to the development of environment and climate risk management guidance and best practices in the financial sector for use both within and outside its membership.
8 See https://www.fhfa.gov/AboutUs/Reports/ReportDocuments/FHFA_StrategicPlan_2022-2026_Final.pdf.
9 ESG encompasses considerations of environmental, social, and governance factors. For the Enterprises, ESG covers their work to enhance environmental sustainability within the homes they finance, to advance consumer access to safe, resilient, and affordable housing opportunities in a sustainable manner, and to embed climate considerations within their board and management processes.
10 Fannie Mae’s 2023-2025 Strategic Plan is referenced in its 2022 Annual Report on Form 10-K (pp. 4) at https://www.fanniemae.com/media/46276/display.
11 See https://fhlbanks.com/the-federal-home-loan-banks-inaugural-corporate-social-responsibility-report/.?
12 See https://www.fhlb.com/getmedia/9cd26f43-96eb-4ac0-9dad-e109fd4abdb5/FHLBank-ESG-Report.pdf.
Authored by: Eric Kelley
Senior Strategic Analyst, Division of Conservatorship Oversight and Readiness
Authored by: Anne Marie Pippin
Deputy Director, Division of Conservatorship Oversight and Readiness
Authored by: La’Toya Holt
Senior Risk Analyst, Governance and Management Risk Branch, Office of Risk Analysis, Policy and Guidance and Development, Division of Enterprise Regulation
Editor: Varun Joshi
Economist, Climate Change and ESG Branch
Boooom ! - 
They are a bunch of "ashols." If they didn't believe this was relevant, why did they even defend the case in the first place?
There are always capital requirements. The thresholds are statutory.
Not binding, but FnF have to build capital retaining earnings (Core Capital) once they've been generated.
There is no switch on/off button either.
And no. What the FHFA/UST are doing isn't legal. The Separate Account plan is what is legal, pending unwinding it.
You are showing the ERCF based on the illegal Government theft story that you and other plotters defend in court.
Instead, with the Separate Acct plan, CET1 >2.5 % of ATA.
English much?
One thing is that the FHFA suspended the Capital Classifications in 2008 and the capital requirements aren't binding, which is typical of conservatorship, pursuant to the "may" in the FHFA-C's Power: "may put FnF in a sound and solvent condition" and also the FHFA-C's Incidental Power: "Any action authorized by this section, in the best interests of FnF or the FHFA". That is, it's necessary so that the conservator has some leeway to administer the conservatorship, at the time when the companies and the economy are bleeding and still do and in need to fix their operations, organization,...15 years later, that's why the FHFA director still needs the powers and rights from FnF and ours.
In other words, this way, the conservator isn't tied up.
And a different thing is that:
1- The capital requirements must be published because they are statutory (FHEFSSA). This is why FnF have posted the Minimum (Leverage) Capital requirement on their Earnings reports every quarter since day one. The Risk-Based Capital requirement was missing because HERA struck the entire section in the FHEFSSA with the formulaic, with the mandate to the director to come out with a new one.
Not "binding" but they are good to know.
Freddie Mac:
2- You seem to suggest that, because there are no capital requirements, FnF aren't required to build capital. Then, you can take all their capital generated away. Even without thresholds (requirements), they have to build capital.
This is the typical "playing with the words" by the Fanniegate attorneys we are used to. We need to know the thresholds to track the capital shortfall, evaluate their soundness and solvency and to uphold the FHFA-C's power (which means to restore the capital levels: recapitalization), and I've already mentioned that "may" is imperative once the capital has been generated and not a choice, in the legal dictionary.
That is, the statutory capital levels are financial indicators of the financial condition in a financial company.
3- The suspension of Capital Classifications doesn't mean that the statutory section "Capital Classifications" was suspended or repealed, which is another take by the Fanniegate attorneys, where all the definitions regarding capital are set forth, so we learn that the Minimum (Leverage) capital requirement is met with Core Capital and added in the Capital Rule, the CET1 Capital and Tier1 capital; that the Risk-Based Capital requiement is met with Total Capital; that there is a Critical Capital level called "irrelevant" by the FHFA because it triggers a conservatorship during a conservatorship, but it forgot that it needs to be published regardless, currently illegally absent from the ERCF.
They aren't met with the capital metric "Capital Reserve".
The plotters don't like the rules, this is why the Mnuchin Treasury Department recommended Congress to repeal these FHEFSSA definitions in its 2019 UST Plan at the request of a Presidential Memorandum, which attempted to substitute the real 2011 UST 3-option Privatized Housing Finance System for the release, at the request of the Dodd-Frank law and a Report to Congress.
4- The key for the suspension of Capital Classifications that didn't bother to anyone in the first place: somehow the plotters think that, pretending that it was the FHEFSSA section Capital Classifications what was suspended too, commented before, the Restriction on Capital Distributions (U.S.Code §4614(e)) was repealed too, because, HERA, surprisingly, inserted it at the end of the section, whereas the same provision is a stand alone section: Prompt Corrective Action in the banks' FDI Act.
HERA:
5- Likewise, the fact that it took 12 years for the FHFA director to come up with the changes in the capital requirements of the FHEFSSA (18-Month Implementation section, missing), that it was authorized/mandated to carry out in an amendment inserted by HERA (Capital Rule effective February 16, 2021), doesn't mean that FnF don't have to build capital for their financial rehabilitation in the meantime. That is, the typical Transition Period to build capital given by any Federal Agency when there are changes, and the Equity holders have suffered Regulatory Risk (Basel framework for capital requirements, in light of the 2011 UST Plan). It has just made it a "Back-end Capital Rule".
Besides Conservator Risk, not only for the Separate Account plan (Legal, except the 7 Securities Law violations in the process), but also for the extended period beyond what would have been reasonable thresholds for the release (Undercapitalized: C.C. or Tier 1 Captial > 2.5% of ATA. Mandatory release in the prior FHEFSSA; or the resumption of dividend payments afterwards), but "in the best interests of the FHFA" (membership cleansing) it has been extended to CET1 > 2.5% of ATA, so FnF can redeem the JPS (AT1 Capital) and still meet the ERCF with Tier 1 Captial > 2.5% of ATA.
Wait! Because it was extended one quarter more to 4Q2023, so that the laggard Fannie Mae meets the threshold for the resumption of dividend payments (25% of the Prescribed Capital Buffer. Table 8: Payout ratio) after the redemption of JPS, and under the Separate Account plan.
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Fannie Mae (the Federal National Mortgage Association, or FNMA) is a government-sponsored enterprise (GSE) in the U.S. that was established in 1938. Its main purpose is to provide liquidity, stability, and affordability to the U.S. housing market. It does this by purchasing mortgages from lenders (like banks), packaging them into mortgage-backed securities (MBS), and selling those securities to investors. This process ensures that lenders have more capital to issue new home loans, helping more Americans get access to homeownership.
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