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1 1 (February 14, 2022)

handle is hein.amenin/aeiaegk0001 and id is 1 raw text is: ENTEF.RPRSE
Comment to
Office of the Comptroller of the Currency
on
Risk Management: Principles for Climate-
Related Financial Risk Management for Large
Banks
OCC Docket ID OCC-2021-0023
Benjamin Zycher
Senior Fellow, American Enterprise Institute
February 14, 2022
Estimation of climate risks by financial institutions
would be futile, politicized, distorted by an imperative to avoid
regulatory and litigation threats, and largely arbitrary, and thus
would not serve the security, soundness, and systemic stability
goals of OCC regulation.
Submitted through the federal eRulemaking Portal at https://regulations.gov/
The American Enterprise Institute (AEI) is a nonpartisan, nonprofit, 501(c)(3) educational organization and
does not take institutional positions on any issues. The views expressed in this testimony are those of the
author.

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