MBA and NYMBA Comment Letter on Proposed NYDFS Climate Risk Mitigation Guidance

MBA comments on the New York Department of Financial Services’ 

(NYDFS) Proposed Guidance for New York State-Regulated Banking and Mortgage Institutions Relating to Management of Material Financial Risks from Climate Change. The Mortgage Bankers Association (MBA)1 and the New York Mortgage Bankers Association (NYMBA) are supportive of efforts to ensure financial institutions are prepared for the uncertainties of climate change and appreciate the leadership of policy makers like NYDFS in raising these complicated issues and the need for solutions.