Table 3.
Climate stress testing effectiveness and capacity
Criteria | Bank of England | US Federal Reserve | |
---|---|---|---|
Scope | Systemically important and materially climate-exposed financial institutions | Large UK banks, building societies, and general and life insurers | Largest and most complex US banks; scope could be expanded via FSOC designation and scenarios could inform broader US stress testing regime |
Scenario Design and Modeling Approach | Physical and transition risks with appropriate spatial and temporal resolution and robust representation of uncertainty and interdependencies | Three scenarios combining physical and transition risks over a 30-year time horizon with 5-year reporting intervals and a static baseline balance sheet; separate analysis of litigation risks for general insurers | Climate scenarios could be implemented as part of the comprehensive macro scenario or as an added component; necessitates the development of threat-specific narratives for climate risks and transmission pathways |
Metrics | Performance-based and decision-relevant metrics derived from quantitative and qualitative outputs | Quantitative metrics include changes in banking book assets for banks and liabilities and assets for insurers; qualitative metrics include climate risk measurement and management assumptions and approaches for participants and selected counterparties | Existing capital-based metrics could be used to assess performance, but disaggregated balance sheet impacts and broader risk management processes may be more informative; additional metrics should be considered as climate risk data, methodologies, and frameworks advance |
Systems Analysis | Firm-level analysis enables system-level modeling of the effects of climate change on financial stability via risk aggregation and amplification | Facilitated by concurrent application and detailed reporting for banks and insurers, as well as follow-on data collection to assess system-wide interactions, inconsistencies, and financial stability implications | Requires expansion, but the scope and concurrent application could facilitate analysis of second-round effects and the counterparty analysis could be expanded to improve the measurement of system-wide interactions and financial stability implications |
Market Discipline | Incentivizes improved risk management practices and enables price corrections via disclosure | Increased climate risk awareness among participating firms via individual feedback and integration into supervisory assessment; potential for price corrections limited by aggregate disclosure | Granular disclosure could facilitate market discipline among participating firms and their stakeholders |
Mitigation Evaluation | Firms articulate and assess the effectiveness of alternative strategies to increase resilience to climate risks | Static balance sheet in the first round, but articulation of potential management actions in the second round and documentation of assumptions about counterparties’ actions | Mitigations could be represented in capital planning via dynamic balance sheets, as well as in expanded use of the qualitative assessment to include climate risk management processes |
Evidence-Based Regulation | Supports the monitoring of climate-related systemic risk accumulation and propagation and informs the design and implementation of microprudential and macroprudential standards | Monitoring the accumulation and propagation of climate-related systemic risk is an explicit purpose; not used for calibrating firm- or system-level capital standards (routine stress tests are used to calibrate these requirements), but will inform interagency and international cooperation on climate-related financial risk regulation | Monitoring the accumulation and propagation of systemic risk is an explicit purpose (but routine stress tests are not used to calibrate macroprudential requirements); could be used to calibrate microprudential capital standards with sufficiently robust measurement approaches |