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A Bird Eye (Re)view of Key Readings

April 26, 2022 by José Manuel Mansilla-Fernández

This journal section indicates a few and briefly commented references that a non-expert reader may want to cover to obtain a first informed and broad view of the theme discussed in the current issue. These references are meant to provide an extensive, though not exhaustive, insight into the main topics of the debate. More detailed and specific references are available in each article published in the current issue.

On the relevance of climate change risks

Understanding the effects of climate change on the financial system has emerged as one of the forefront issues globally (Hong et al., 2019, 2020). Climate change is believed to increase the frequency and intensity of extreme weather events, raise average temperatures, and rising sea levels. Importantly, climate change already impacts economic and financial outcomes, which might have negative repercussions on financial systems. Correlated risks from climate change shocks could have effects beyond individual banks and borrowers to the broader financial system and economy. In this regard, in the pricing of residential mortgages does not incorporate climate change risks, a sudden correction could result in large-scale losses to banks, leading to reduced lending supply and jeopardizing financial stability. The subsequent declines in wealth could amplify the effects of climate change on the real economy, thus producing knock-on effects on financial markets (Nguyen et al., 2021).

Financial institutions must assess their vulnerabilities to relevant climate risks, as well as risks’ likely persistent and breadth, to be able to continue meeting the financial needs of households and companies when hit by disruptions caused by climate change. Remarkably, considering climate risks is relevant from the regulatory point of view. In this vein, the Federal Reserve created a dedicated supervision climate committee to observe the risks of climate change to individual banks. Likewise, the Bank of England expects its banks to understand and assess the financial risks related to climate change (Nguyen et al., 2021).

The recent studies are focused on exploring the ex-post effects of acute hazards, e.g., storms, floods, wildfires, on banks. In this regard, North and Schüwer (2018) show that natural disasters weaken financial stability. Similarly, Issler et al. (2020) find an augment in mortgage delinquency and foreclosure after wildfires. Ouazad and Kahn (2021) find that lenders are more likely to approve mortgages that can be securitized after hurricanes. Unlike acute hazards, the chronic ones -e.g., slow increases in sea levels- introduce the possibility that losses may arise from natural disasters. Despite the risk of chronic hazards causing losses, economists still know little about how such risks are priced ex-ante by banks. Consequently, more research is needed to understand how climate risk can be priced -ante by financial institutions, particularly the pricing of loans.

Interestingly, banks may not be able to price long-term climate change risks. The Board of Governors of the Federal Reserve System (2020a, b) estates that banks’ models still lack the necessary geographic precision or horizons to price climate risks. Another challenge can be uncertainty regarding the time horizon over climate risk can be materialized (Barnett et al., 2020). Furthermore, many banks still rely on traditional backward-looking models based on historical exposures, which might not adequately reflect climate risks’ complex and continuous changing nature. Moreover, considering the set of risks that banks are currently facing -e.g., cybersecurity, geopolitical risks, and risks associated with the credit cycle-along with the relative long-term horizon around climate change and risk (Nyberg and Wright, 2015). For instance, sea levels rise is a non-conventional risk and therefore, lenders pay equal attention to this risk or incorporate it into their pricing loan decisions (Jiang et al., 2020).

On carbon pricing and its repercussions on lending

Research on carbon risk is still embryonic. Stranded assets are physical assets whose value declines substantially due to climate risk. The carbon reduction requirements in the Paris Agreement and the policies oriented to fossil fuel firms might not be able to fully utilize their existing fossil fuel reserves (McGlade and Ekins, 2015), leading to a decline in the financial values of such reserves. The carbon risk from stranded assets in the fossil fuel industry can be priced, which constitutes an approach for assessing climate-related financial risks. However, carbon risk goes beyond stranded assets. Firms issuing large volumes of carbon are relatively more likely to suffer financial penalties if environmental policies tighten. Direct penalties can result from additional costs of carbon taxes on firms’ emissions. These can apply to firms in all industries with a carbon footprint and are not limited to fossil fuels producers (Ehlers et al., 2021).

The pricing of carbon risk in the loan markets changed significantly after the Paris Agreement.[1]See the Institutions section in this issue. The difference in risk premia due to carbon emission intensity is apparently across industry sectors. Additionally, this phenomenon is broader than simply stranded assets in fossil fuel emissions or other carbon-intensive industries. Including loans fees and the premium is not prevalent in the years before the Paris Agreement, which increased banks’ awareness of carbon risk (Krueger et al., 2020). However, Delis et al. (2021) assess syndicated loan data for fossil fuel firms to investigate whether banks price the risk of stranded assets.[2]The corporate loan market, and specially the syndicated loans markets, constitutes an ideal laboratory to test hypotheses about the effects of climate change / risk on loan pricing, because banks … Continue reading They reveal that only after the 2015 Paris Agreement banks started pricing the risk of stranded assets related to fossil fuel reserves. Similarly, Kleimeier and Viehs (2018) also use syndicated loans data to investigate if forms voluntarily disclose their carbon emissions to the Carbon Disclosure Project, which allows them to reduce their cost of credit compared to non-disclosing firms. This result supportcs Antoniou et al. (2020), who theoretically find that loans spreads for firms participating in cap-and-trade programs function the cost of compliance and the specific features of the permits markets. Using the EU Emission Trading System, which is designed to pass the cost of CO2 emissions to polluters, this study suggests that the higher permits storage and lower permit prices, the lower firm financing costs.

Importantly, banks have started to internalize possible risks from the transition to a low-carbon economy across various industries. Krueger et al. (2020) suggest that carbon emissions indirectly caused by production inputs were not priced at the margin, suggesting that the overall carbon footprint is less of a concern to banks those direct missions. Likewise, Bolton and Kacperczyk (2021) find that the likelihood of disinvestment by institutional investors significantly augments with the degree and intensity of emissions directly attributable to firms. This suggests potential for ‘green-washing’ since the aforementioned emissions mentioned above can be reduced simply by outsourcing carbon-intensive activities withoutlowering the firm’s carbon footprint (Ben-David et al., 2018).

On the impact of climate change on equity markets

So far, research on the pricing of climate change risk, including carbon risk, has focused on the pricing of climate-related risks in equity markets. Recently, economists indicated that a transition risk premium in equity and option markets, which seems to be more pronounced in times of high climate change awareness. Mainly, the price of protection of option securities against the downside tail risk is higher for carbon-intense firms. In this regard, Bolton and Kacperczyk (2021) identify a carbon premium in the cross-section of the US stock market over the last decade. Particularly, the 2016 US climate policy shocks (the Trump election who appointed Scott Pruit, a climate sceptic, as administrator of the US Environmental Protection Agency) provide additional evidence that firms’ exposure impacts on their stock market valuation (Ramelli et al., 2021). Consequently, the valuation of carbon-intense firms rose. Goergen et al., (2020) assess carbon risk measures based on the firm’s overall strategy and its operational exposure to transition risk, including carbon emissions. Although they find that carbon risk is a priced risk factor, it does not find any evidence for a carbon premium in the global equity market.

On the capacity of banks to boost the climate change

As major providers of credit, banks are the key players in the effort to transition from a brown to a green economy. The momentum established by the COP21 enlarges the set of investment opportunities to finance green projects and renewable energy. Indeed, investment in the green economy has recently increased and is expected to grow enormously in market share (IEA, 2015; International Renewable Energy Agency, 2016). This increase is motivated by a growing consensus that supports movements towards a low-carbon economy and technological improvements that will lead to cost reductions in renewable energy, making alternatives to fossil fuel more appealing (Mazzucati and Perez, 2015; Krueger et al., 2015).

This might raise the question of how climate risks might directly impact financial institutions. Importantly, banks take on new risks in this regard, particularly physical and transition risks. On the one hand, physical risks arise from weather and climate-related disasters (Nordhaus, 1977; Stern, 2008; Nordhaus, 2019). These events can damage properties, reduce agricultural productivity, and impact deleteriously on human assets (Deryugina and Hsiang, 2014; O’Neil et al., 2017). Should this reduce the firms’ profitability and deteriorate their balance sheets, banks would be negatively affected in terms of asset values, collateral quality, and credit risk exposure. Furthermore, banks suffering large losses could diminish their lending availability, thus exacerbating the financial impact of physical risks by reducing credit supply. The blossoming literature provides theoretical and empirical evidence that banks should consider such physical risks in their investment decisions. Accordingly, Addoum et al. (2019) and Pankratz et al. (2019) show a negative correlation between firms exposed to extreme temperatures and profitability. Balvers et al. (2017) find that firms suffering from relatively high temperatures have higher cost of capital. This result connects with the literature advocating that extreme weather events are incorporated to stock and option markets (Dell et al., 2014; Kruttli etal., 2019; Choi et al., 2020).

On the other hand, banks should face transition risks that might arise from adjustments made toward developing a green economy. Particularly, transition risk depends on the timing and the speed of the process. Unanticipated changes in climate polices, regulations, technologies, and market sentiment could reprice the value of bank assets (CISL, 2019; Hong et al., 2019). Consequently, banks exposed to climate-sensitive sectors might be forced to fire carbon-intensive assets, leading to liquidity problems (Pereira da Silva, 2019). Therefore, this could create uncertainty and procyclicality and increase banks’ market risk (BoE, 2018). Transition risks could impact on bank credit risk if new technologies or changes in consumer behaviour towards “environmentally friendly” sectors lowered carbon-intensive firms’ profitability, further increasing their default risk (Krueger et al., 2020). Reghezza et al. (2021) analyse whether climate-oriented regulatory policies impact the flow of credit towards polluting corporations. Following the Paris Agreement, they find that European banks reallocated credit away from polluting companies. Consequently, green regulatory initiatives in banking can significantly impact on combating climate change.

Importantly, the COP21 is expected to impact the banking sector’s decisions. De Greiff et al. (2018) and Degryse et al. (2020a, b) assess the effect of climate risks on pricing in the syndicated loans. Since the COP21, banks have charged a premium for climate risk driven by increased awareness of climate policy-related risks. In particular, green firms have borrowed at comparatively lower prices since COP21 came into force.
Likewise, Delis et al. (2018) analysed the risk stemming from stranded fossil reserves, suggesting that, after 2015, banks started to price climate policy exposure by raising the cost of credit due to their awareness of transition risk. Ilhan et al. (2018), using a sample of high-emission industries in the S&P 500 before and after COP21, find that investors already incorporate information on climate-related risks when assessing risk profiles. Ginglinger and Moreau (2020) show that, after COP21, French companies subject to large climate risks reduced their leverage.

Regarding the financial system structure, De Haas and Popov (2019) find evidence of relatively lower CO2 emissions in more equity-funded economies, and they argue that stock markets contribute to reallocating investments toward less polluting industries. Similarly, Mesonnier (2019) investigates whether French banks reallocate credit from low intensive industries over the 2010-2017 period. They find that French banks reduce credit provision to more polluting industries.

References

Addoum, M. J., Ng, T. D. and Ortiz-Bobea, A. (2020). Temperature shocks and establishment sales. The Review of Financial Studies, 22: 1331-1336.

Antoniou, F., and Kyriakopoulou, E. (2019). On The Strategic Effect of International Permits Trading on Local Pollution. Environmental and Resource Economics, 74: 1299-1329.

Barnett, M., Brock, W., and Hansen, L. P. (2020). Pricing uncertainty induced by climate change. Review of Financial Studies, 33: 1024-1066.

Ben-David, I., Franzoni, F., and Moussawi, R. (2018). Do ETFs Increase Volatility? Journal of Finance, 73: 2471-2535.

Board of Governors of the Federal Reserve System. (2020a). Statement by Governor Lael Brainard. Available at: https://www.federalreserve.gov/publications/brainard-comment-20201109.htm (Accessed on February 2, 2022).

Board of Governors of the Federal Reserve System’s Financial Stability Report, November (2020b). See: https://www.federalreserve.gov/publications/files/financial-stability-report-20201109.pdf (Accessed on February 2, 2022).

BoE (2018). Transition in thinking: The impact of climate change on the UK banking sector. Bank of England Report, September 2018.

Bolton, P., and Kacperczyk, M.T. (2020). Do investors care about carbon risk? Journal of Financial Economics, 142: 517-549.

Choi, D., Gao, Z., and Jiang, W. (2020). Attention to global warming. The Review of Financial Studies, 33: 1112-1145.

CISL (2019). Unhedgeable risk: How climate change sentiment impacts investment. Cambridge Institute for Sustainability Leadership, Cambridge.

De Greiff, K., Ehlers, T. and Packer, F. (2018). The pricing and term structure of environmental risk in syndicated loans. Mimeo, Bank for International Settlements.

De Haas, R. and Popov, A. (2019). Finance and Carbon Emissions. ECB Working Paper Series, No 2318. Available at: https://www.ecb.europa.eu/pub/pdf/scpwps/ecb.wp2318~44719344e8.en.pdf (Accessed on February 2, 2022).

Degryse, H., Goncharenko, R., Theunisz, C. and Vadasz, T. (2020). When green meets green. Centre for Economic Policy Research. https://cepr.org/active/publications/discussion_papers/dp.php?dpno=16536

Degryse, H., Roukny, T. and Tielens, J. (2020), Banking barriers to the green economy. NBB Working Papers, No 391. Available at: https://www.nbb.be/en/articles/banking-barriers-green-economy (Accessed on February 2, 2022).

Delis, D. de Greiff, K., Iosifidi, M., and Ongena, S. (2021). Being Stranded with Fossil Fuel Reserves? Climate Policy Risk and the Pricing of Bank Loans. Swiss Finance Institute Research Paper No. 18-10. DOI: http://dx.doi.org/10.2139/ssrn.3125017

Delis, M., De Greiff, K., and Ongena, S. (2018). Being stranded on the carbon bubble? Climate policy risk and the pricing of bank loans. Swiss Finance Institute Research Paper Series, No 18-10, Swiss Finance Institute. DOI: http://dx.doi.org/10.2139/ssrn.3125017

Dell, M., Jones, F. B., and Olken, B. (2014). What do we learn from the weather? The new climate-economy literature. Journal of Economic Perspective, 52: 740-798.

Deryugina, T., and Hsiang, M. S. (2014). Does the environment still matter? Daily temperature and income in the United States. NBER Working Papers, No 20750, National Bureau of Economic Research, December. DOI 10.3386/w20750

Ehlers, T., Packer, F., and Greiff, K. (2021). The pricing of carbon risk in syndicated loans: which risks are priced and why? BIS Working Papers No 946. Available at: https://www.bis.org/publ/work946.pdf (Accessed on February 2, 2022).

Ginglinger, D., and Moreau, Q. (2019). Climate risk and capital structure. Mimeo.

Goergen, M., Jacob, A., Nerlinger, M., Riordan, R., Rohleder, M., and Wilkens, M. (2020). Carbon risk. Working Paper. Available at: https://www.frbsf.org/economic-research/events/2019/november/economics-of-climate-change/files/Paper-6-2019-11-8-Riordan-1PM-2nd-paper.pdf (Accessed on February 2, 2022).

Hong, H., Karolyi, G. A., and Scheinkman, J. A. (2020). Climate finance. Review of Financial Studies, 33: 1011-1023.

Hong, H., Li, F. W., and Xu, J. (2019). Climate risk and market efficiency. Journal of

Econometrics 208: 265-281.

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Ilhan, E. Z. S., and Vikov, G. (2018). Carbon tail risk. SSRN Electronic Journal.

Issler, P., Stanton, R., Vergara-Alert, C., and Wallace, N. (2020). Mortgage Markets with Climate-Change Risk: Evidence from Wildfires in California, Working paper. DOI: http://dx.doi.org/10.2139/ssrn.3511843

Jiang, F., Li, C. W., and Qian, Y. (2020). Do costs of corporate loans rise with sea level? Working paper. DOI: http://dx.doi.org/10.2139/ssrn.3477450

Kleimeier, S., and Viehs, M. (2018). Carbon Disclosure, Emission Levels, and the Cost of Debt. DOI: http://dx.doi.org/10.2139/ssrn.2719665

Krueger, P., Sautner, Z., and Starks, L.T. (2020) The Importance of Climate Risks for Institutional Investors. The Review of Financial Studies, 33: 1067–1111.

Kruttli, S. M., Tran, R. B., and Watugala, W. S. (2019). Pricing Poseidon: Extreme weather uncertainty and firm return dynamics. Finance and Economics Discussion Series, No 2019-054, Board of the Federal Reserve System.

Mazzucato, M., and Perez, C. (2015). Innovation as growth policy. The Triple Challenge for Europe. In Fagerberg, J., Laestadius, S., and Martin, B.R.: 229-264. DOI: 10.1093/acprof:oso/9780198747413.001.0001

McGlade C, and Ekins P. (2015). The geographical distribution of fossil fuels unused when limiting global warming to 2 °C. Nature. Jan 8;517(7533):187-90. DOI: 10.1038/nature14016. PMID: 25567285.

Mesonnier, J. S. (2019). Banks’ climate commitments and credit to brown industries: new evidence for France. Banque de France Working Papers, No 743, Paris, November. DOI: http://dx.doi.org/10.2139/ssrn.3502681

Nguyen, D.D., Ongena, S., Qi, S., and Sila, V. (2021). Climate Change Risk and the Cost of Mortgage Credit. Swiss Finance Institute Research Paper Series N°20-97. DOI: http://dx.doi.org/10.2139/ssrn.3738234

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Nordhaus, W. D. (2019). Climate change: The ultimate challenge for economics. American Economic Review, 109: 1991-2014.

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Nyberg, D., and Wright, C. (2015). Performative and political: Corporate constructions of climate change risk. Organization, 23: 617-638.

O’Neil, C. B., Kriegler, E., Ebi, L. K., Kemp-Benedict, E., Riahi, K., Rothman, S. D., Van Ruijven, J, B., Van Vuuren, D. P., Birkmann, J., Kok, K., Levy, M., and Solecki, W. (2017). The roads ahead: Narratives for shared socioeconomic pathways describing world futures in the 21st century. Global Environmental Change, 42: 169-180.

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Pereira da Silva, L. (2019). Research on climate-related risks and financial stability: An epistemological break? Based on remarks at the Conference of the Central Banks and Supervisors Network for Greening the Financial System (NGFS).

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Footnotes[+]

Footnotes
↑1 See the Institutions section in this issue.
↑2 The corporate loan market, and specially the syndicated loans markets, constitutes an ideal laboratory to test hypotheses about the effects of climate change / risk on loan pricing, because banks that are the lead arrangers of syndicated loans are informed and incentivized to monitor, and data are widely available (Delis et al., 2021).

Filed Under: 2021.2, From the Editorial Desk

Institutions

April 26, 2022 by José Manuel Mansilla-Fernández

Recent international commitments to climate change

The United Nations (UN hereafter) Climate Change Conference (COP26), which was held in Glasgow (UK), brought together many of the world’s leaders to address concerning issues related to climate change. The headline decision of COP 26 was the Glasgow Climate Pact, an initiative of the UK COP Presidency to capture progress beyond the formal agenda. The Intergovernmental Panel on Climate Change (IPCC) released a report in 2018 that identified that global emissions would need to reduce to zero level by at least 2050 to retain a ‘high-confidence’ level to limit the rise of temperatures to sustainable levels (Masson-Delmotte et al., 2018). The US Treasury Secretary Janet Yellen stated that “rising to this challenge will require the wholesale transformation of our carbon-intensive economies” and that “addressing climate change is the greatest economic opportunity of our time.” (COP26, 2021; Depledge et al., 2022).[1]The World Economic Forum and PwC released jointly the Harnessing Technology for the Global Goals report that identified the significant role that digital technology can play in improving resilience … Continue reading

On the heels of the COP26 Finance Day, the banking industry leaders also met in Glasgow to discuss the leadership role of the banking sector toward net-zero emissions.UN-convened Net-Zero Banking Alliance also committed to coordinating climate actions for financial institutions and aligning their lending and investments portfolios with zero-net emissions by 2050. At the time of writing this note, the Alliance brings together around 100 banks worldwide, representing over 40% of global banking assets. The Alliance acknowledges the crucial role of banks in supporting the transition of the real sector to a greener economy (see Beyene et al., this issue).

The European Commission’s sustainable finance strategy

The High-Level Expert Group on sustainable finance was created in 2016 and included members from the civil society, the financial sector, and the Academia from international institutions.[2]The European Commission defines sustainable finance as the process of dully taking environmental and social contemplations into account when making long-term decisions in sustainable activities … Continue reading Notably, the 2018 group’s final report established the pillars for the Action Plan on Financing Sustainable Growth, which is intended to develop the European Union’s sustainable finance strategy and to incorporate environmental, social, and governance (ESG) considerations into the European financial system (European Commission, 2019, González-Martínez, 2021). The Taxonomy Regulation (Regulation (EU) 2020/852 of June 2020) is the cornerstone of the whole Action Plan since it establishes the classification system for the ‘sustainable’ economic activities.[3]See also Regulation (EU) 2019/2088 and Regulation (EU) 2019/2089.[4]In this regard, the European Commission introduced two supplements. First, the Commission Delegated Regulation (EU) 2021/2139 supplements Regulation 2020/852 by establishing the technical screening … Continue reading Interestingly, the EU Ecolabel for retail financial products is dedicated to expressing investors’ preferences regarding sustainability and the more straightforward access to sustainable products.

Disclosures

The Financial Stability Board created the Task Force on Climate-related Financial Disclosures (TCFD), which provides recommendations for assessing and reporting their climate-related strategy.[5]Disclosures of the financial impacts of climate-related and environmental risks are crucial for achieving the transparency necessary to preserve market discipline. In other words, promoting peer … Continue reading In particular, the final report makes sector-specific recommendations on how companies should disclose climate-related financial risks to inform better their investors, lenders, and insurers (Campiglio, 2016; Campiglio et al., 2018). Notably, the PCAF Global Greenhouse Gas Accounting and reporting Standard for the Financial industry offers detailed statistics on measures and disclose emissions for specific assets. The Science Based Target initiative (SBTi) published the Financial Sector Science-Based Targets Guidance which enables companies to set emissions reductions targets according to the foremost climate science (SBTi, 2021).

The European Commission adopted in April 2021 a proposal for Corporate Sustainability Reporting Directive (CSRD) that introduces stricter reporting requirements and widens the scope of applicability with respect to the existing non-financial reporting directive (NFRD). Furthermore, Regulation (EU) 2019/2088 will apply from March 2021. Regarding the development of a European Union Green Bond Standard, in early July 2021 the European Commission presented its proposal based on a voluntary framework that remarks transparency, the need for external review, and the European Securities and Markets Authority should supervise it.

Remarkably, integrating ESG risks into the Supervisory Review and Evaluation Process (SREP) performed under the Pillar 2 as not exempt from difficulties. However, the EC has considered these recommendations in developing the EU Banking Package that finalises the implementation of Basel III in Europe. Formally, Pillar 3 disclosure requirements are expanded from applying to large, listed institutions to all in the scope of the CRR (EBA, 2021; Marullo Reedtz, this issue). Importantly, as a part of the Pillar 3 disclosure and the NFRD, the Green Asset Ratio measures the “greenness” of the bank’s balance sheet, and it will allow investors and regulators to evaluate and foster new legislation toward green finance. Recently, in January 2022 the European Banking Authority (EBA) released the final draft of the Implementing Technical Standards (ITS) on Pillar 3 disclosures on ESG risks (Mikkelsen et al., this issue).

The role of central banks

Globally, the Network of Central Banks and Supervisors for Greening the Financial System (NGFS) in December 2017 was aimed at defining and promoting good practices, conducting analysis, fomenting climate risk management in the financial sector, and mobilising funds needed for a transition towards a sustainable economy (NGFS, 2021). In Europe, the national central banks incorporate climate-related questions intro their actions. Furthermore, central banks not belonging to the Eurosystem are even introducing environmental questions into their design of the monetary policy. Central banks have begun integrating sustainable and responsible investment (SRI) principles into their portfolio management (NGFS, 2019, 2020). Outstandingly, the European Central Bank is progressing in evaluating and limiting the potential aftermaths of climate change (ECB, 2021a,b; Reghezza et al., 2021).The European Central Banks is advancing on preparing and executing the ECB Thematic Review on Climate-Related and Environmental (C&E) Risks and the ECB Climate Stress tests that include transition and physical risks in a horizon of 30 years. Accordingly, the SSM included climate-related risks in its 2019 and 2020 roadmaps that draw up supervisory expectations for relevant banks (Alonso and Marqués, 2019; Gonzalez and Núñez, 2020, 2021).

References

Alonso, A., and Marques, J.M. (2019). Financial innovation for a sustainable economy. Occasional paper No. 1916. Bank of Spain. Available at: https://www.bde.es/f/webbde/SES/Secciones/Publicaciones/PublicacionesSeriadas/DocumentosOcasionales/19/Files/do1916e.pdf (Accessed on April 18, 2022).

Beyene, W., Delis, M., and Ongena, S. (2021). Disclosure of banks fossil exposures. European Economy – Banks, Regulation and the real Sector, this issue.

Campiglio, E. (2016). Beyond carbon pricing: The role of banking and monetary policies in financing the transition to a low-carbon economy, Ecological Economics 121, 220-230. DOI: https://doi.org/10.1016/j.ecolecon.2015.03.020

Campiglio, E., Dafermos, Y., Monnin, P., Ryan-Collins, J., Schotten, G., and Tanaka, M. (2018). Climate change challenges for central banks and financial regulators. Nature Climate Change 8, 462-468. DOI: https://doi.org/10.1038/s41558-018-0175-0

COP26. (2021). COP26 Goals. Available at: https://ukcop26.org/cop26-goals. (Accessed on April 18, 2022).

Depledge, J., Saldivia, M., and Peñasco, C. (2022). Glass half full or glass half empty?: The 2021 Glasgow Climate Conference, Climate Policy, 22, 147-157, DOI: 10.1080/14693062.2022.2038482

European Central Bank (2020). ECB report on institutions’ climate-related and environmental risk disclosures. Available at: https://www.bankingsupervision.europa.eu/ecb/pub/pdf/ssm.ecbreportinstitutionsclimaterelatedenvironmentalriskdisclosures202011~e8e2ad20f6.en.pdf (Accessed on April 18, 2022).

European Central Bank (2021a). Climate-related risk and financial stability. ECB/ESRB Project Team on climate risk monitoring. Available at: https://www.ecb.europa.eu/pub/pdf/other/ecb.climateriskfinancialstability202107~87822fae81.en.pdf (Accessed on April 18, 2022).

European Central Bank (2021b). Detailed roadmap of climate change-related actions. Available at: https://www.ecb.europa.eu/press/pr/date/2021/html/ecb.pr210708_1_annex~f84ab35968.en.pdf (Accessed on April 18, 2022).

European Commission (2019). Guidelines on reporting climate-related information. Available at: https://ec.europa.eu/finance/docs/policy/190618-climate-related-information-reporting-guidelines_en.pdf (Accessed on April 18, 2022).

González-Martínez, C.I. (2021). Overview of global and European institutional sustainable finance initiatives. Bank of Spain. Available at: https://www.bde.es/f/webbde/SES/Secciones/Publicaciones/InformesBoletinesRevistas/ArticulosAnaliticos/21/T3/Files/be2103-art30e.pdf (Accessed on April 18, 2022).

González, C. I., and S. Núñez (2020). Cambio climático y sistema financiero: una necesaria mirada al futuro. Papeles de Economía Española No 163, pp. 130-145. Available at: https://www.funcas.es/articulos/cambio-climatico-y-sistema-financiero-una-necesaria-mirada-al-futuro-transicion-hacia-una-economia-baja-en-carbono-en-espana-2019-n-163/ (Accessed on April 18, 2022).

González, C. I., and S. Núñez (2021). Markets, financial institutions and central banks in the face of climate change: challenges and opportunities. Occasional Paper No. 2126. Bank of Spain. Available at: https://www.bde.es/f/webbde/SES/Secciones/Publicaciones/PublicacionesSeriadas/DocumentosOcasionales/21/Files/do2126e.pdf (Accessed on April 18, 2022).

Marullo Reedtz, P. (2021). Financing the environmental transition in Europe. European Economy – Banks, Regulation and the real Sector, this issue.

Masson-Delmotte, V., Zhai, P., Pörtner, H. O., Roberts, D., Skea, J., Shukla, P. R.,. and Waterfield, T. (2018). Global warming of 1.5C. An IPCC Special Report on the impacts of global warming of, 1(5).

Mikkelsen, D., Viscardi, S., Montes, M., and De Amicis, F.P. (2021). Climate change regulation and supervision in Europe and implications for commercial banks. European Economy – Banks, Regulation and the real Sector, this issue.

NGFS (2019). First comprehensive report. A call for action, April.

NGFS (2021). Annual Report 2020, April.

Reghezza, A., Altunbas, Y., Marques-Ibañez, D., Rodriguez d’Acri, C., and Spaggiari, M. (2021). Do banks fuel climate change? ECB Working Paper Series No. 2550. Available at: https://www.ecb.europa.eu/pub/pdf/scpwps/ecb.wp2550~24c25d5791.en.pdf (Accessed on April 18, 2022).

Science-Based Targets initiative (SBTi). 2021. Financial Sector Science-Based Targets Guidance Pilot Version 1.1, Science-Based Targets initiative (SBTi), Report. Available at: https://sciencebasedtargets.org/resources/files/Financial-Sector-Science-Based-Targets-Guidance-Pilot-Version.pdf (Accessed on April 18, 2022).

World Economic Forum & PwC (2021), Harnessing Technology for the Global Goals: A framework for government action, Accessed on 31st October 2021. Accessed at: https://assets.2030vision.com/files/resources/wef-harnessing-technology-for-the-global-goals-2021.pdf?470b76352b (Accessed on April 18, 2022).

Legislation cited

Commission Delegated Regulation (EU) 2021/2139 of 4 June 2021 supplementing Regulation (EU) 2020/852 of the European Parliament and of the Council by establishing the technical screening criteria for determining the conditions under which an economic activity qualifies as contributing substantially to climate change mitigation or climate change adaptation and for determining whether that economic activity causes no significant harm to any of the other environmental objectives. Available at: http://data.europa.eu/eli/reg_del/2021/2139/oj (Accessed on April 18, 2022).

Commission Delegated Regulation (EU) 2021/2178 of 6 July 2021 supplementing Regulation (EU) 2020/852 of the European Parliament and of the Council by specifying the content and presentation of information to be disclosed by undertakings subject to Articles 19a or 29a of Directive 2013/34/EU concerning environmentally sustainable economic activities, and specifying the methodology to comply with that disclosure obligation. Available at: http://data.europa.eu/eli/reg_del/2021/2178/oj (Accessed on April 18, 2022).

Directive 2014/95/EU of the European Parliament and of the Council of 22 October 2014 amending Directive 2013/34/EU as regards disclosure of non-financial and diversity information by certain large undertakings and groups Text. Available at: https://eur-lex.europa.eu/eli/dir/2014/95/oj (Accessed on April 18, 2022).

European Commission (2019). Communication from the Commission — Guidelines on non-financial reporting: Supplement on reporting climate-related information (2019/C 209/01). Available at: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A52019XC0620%2801%29 (Accessed on April 18, 2022).

European Commission (2018). Communication from the European Parliament, the European Council, the Council, the European Central Bank, The European Economic and Social Committee of the Regions. Action Plan: Financing Sustainable Growth (COM/2018/097 final). Available at: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A52018DC0097 (Accessed on April 18, 2022).

Regulation (EU) 2020/852 of the European Parliament and of the Council of 18 June 2020 on the establishment of a framework to facilitate sustainable investment, and amending Regulation (EU) 2019/2088 (Text with EEA relevance) Available at: https://eur-lex.europa.eu/eli/reg/2020/852/oj (Accessed on April 18, 2022).

Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019 on sustainability‐related disclosures in the financial services sector (PE/87/2019/REV/1). Available at: https://eur-lex.europa.eu/eli/reg/2019/2088/oj (Accessed on April 18, 2022).

Regulation (EU) 2019/2089 of the European Parliament and of the Council of 27 November 2019 amending Regulation (EU) 2016/1011 as regards EU Climate Transition Benchmarks, EU Paris-aligned Benchmarks and sustainability-related disclosures for benchmarks (PE/90/2019/REV/1). Available at: https://eur-lex.europa.eu/eli/reg/2019/2089/oj (Accessed on April 18, 2022).

Regulation (EU) No 575/2013 of the European Parliament and of the Council of 26 June 2013 on prudential requirements for credit institutions and investment firms and amending Regulation (EU) No 648/2012 Text with EEA relevance. Available at: http://data.europa.eu/eli/reg/2013/575/oj (Accessed on April 18, 2022).

Footnotes[+]

Footnotes
↑1 The World Economic Forum and PwC released jointly the Harnessing Technology for the Global Goals report that identified the significant role that digital technology can play in improving resilience to global warming related, natural hazards, reducing emissions, and improving the ability for humans to take the necessary steps to achieve the zero net target (World Economic Forum & PwC, 2021).
↑2 The European Commission defines sustainable finance as the process of dully taking environmental and social contemplations into account when making long-term decisions in sustainable activities (European Commission, 2018). Accordingly, the so-called Capital Markets Union is a priority, and a key step for implementing the Paris Agreement and the European Union’s sustainable agenda.
↑3 See also Regulation (EU) 2019/2088 and Regulation (EU) 2019/2089.
↑4 In this regard, the European Commission introduced two supplements. First, the Commission Delegated Regulation (EU) 2021/2139 supplements Regulation 2020/852 by establishing the technical screening criteria for determining the conditions under which an economic activity qualifies as contributing substantially to climate change mitigation or climate change adaptation and for determining whether that economic activity causes no significant harm to any of the other environmental objectives. Second, Commission Delegated Regulation (EU) 2021/2178 supplements regulation 2020/852 by specifying the content and presentation of information to be disclosed by undertakings subject to Articles 19a or 29a of Directive 2013/34/EU, the methodology to comply with that disclosure obligation.
↑5 Disclosures of the financial impacts of climate-related and environmental risks are crucial for achieving the transparency necessary to preserve market discipline. In other words, promoting peer pressure incentivizes companies to manage and diminish their individual risk (ECB, 2020).

Filed Under: 2021.2, From the Editorial Desk

Numbers

April 22, 2022 by José Manuel Mansilla-Fernández

A sector-based classification approach

Figure 1. European banks’ exposure towards climate-policy-relevant sectors.

Figure 1

Notes: Own elaboration based on the classification of climate-policy-relevant sectors (CPRS) proposed by Battiston et al. (2017)[1]Battiston, S., Mandel, A., Monasterolo, Schütze, F and Visentin, G. (2017). A climate stress-test of the financial system. Nature Climate Change 7: 283-288. DOI: https://doi.org/10.1038/nclimate3255 applied to EU banks’ exposures provided by EBA. The CPRS consists of 8 categories, with different incidence in each sector: 1. Fossil fuel, 2. Utility, 3. Energy-intensive, 4. Buildings, 5. Transportation, 6. Agriculture, 7. Finance and 8. Others. Exposures to categories 1 to 6 are defined as those that may be affected by climate transition risks. The total value of expositions is of 2,346.53 billion of euros.

 

 

 

Figure 2: European banks’ exposure towards climate-policy-relevant sectors by category of climate transition risk.

Figure 2

Notes: Based on the classification of climate-policy-relevant sectors (CPRS) proposed by Battiston et al. (2017)[2]Battiston, S., Mandel, A., Monasterolo, Schütze, F and Visentin, G. (2017). A climate stress-test of the financial system. Nature Climate Change 7: 283-288. DOI: https://doi.org/10.1038/nclimate3255 applied to EU banks’ exposures provided by EBA. The CPRS consists of 8 categories, with different incidence in each sector: 1. Fossil fuel, 2. Utility, 3. Energy-intensive, 4. Buildings, 5. Transportation, 6. Agriculture, 7. Finance and 8. Others. Exposures to categories 1 to 6 are defined as those that may be affected by climate transition risks. The total value of expositions is of 2,346.53 billion of euros.

 

 

 

A greenhouse gas (GHG) emission-based classification approach

Figure 3: European banks’ exposure according to greenhouse gas emission intensity

Figure 3

Notes: Based on EBA. Greenhouse emission intensity buckets applied to EU banks’ exposures provided by EBA. Buckets are defined based on percentiles of the distribution of greenhouse gas, produced by Trucost (S&P Global) https://www.trucost.com (see the table below). The total value of expositions is of 2,346.53 billion of euros.

GHG intensity

 

 

 

Figure 4: European banks’ exposure according to greenhouse gas emission intensity and sector.

Figure 4

Notes: Based on EBA.

 

 

 

A scenario analysis

Figure 5: GDP evolution under different climate scenarios.

Figure 5

Notes: Based on the EBA. The two scenarios represent the difference with respect to orderly transition, and they are built using the parameters sourced from the new ECB climate risk stress test framework, which includes the impact of both the transition and physical risks. The ‘disorderly’ scenario is associated with relatively high costs from a delayed/ineffective transition, and the ‘hot house world’ scenario is when no polices are implemented and natural catastrophes might occur.

 

 

 

Figure 6: Changes in firm-level probability of default with respect to the orderly transition scenario (2020 to 2050).

Figure 6

Notes: Based on EBA. Full bars represent the average increase in the probability of default across firms; dotted bars the increase for firms that are more vulnerable to physical risk. The two scenarios represent the difference with respect to orderly transition, and they are built using the parameters sourced from the new ECB climate risk stress test framework, which includes the impact of both the transition and physical risks. The ‘disorderly’ scenario is associated with relatively high costs from a delayed/ineffective transition, and the ‘hot house world’ scenario is when no polices are implemented and natural catastrophes might occur.

 

 

 

Figure 7: Green asset ratio.

Figure 7

Notes: Based on the EBA. The green asset ratio is constructed for each bank by dividing the green exposure – available only for a subset of exposures – by the total original exposure. The green amount is constructed using either bank’s self-reported data or TAC estimates.

Footnotes[+]

Footnotes
↑1, ↑2 Battiston, S., Mandel, A., Monasterolo, Schütze, F and Visentin, G. (2017). A climate stress-test of the financial system. Nature Climate Change 7: 283-288. DOI: https://doi.org/10.1038/nclimate3255

Filed Under: 2021.2, From the Editorial Desk

Sustainability and Finance – Why and How?

April 22, 2022 by Giorgio Barba Navaretti, Giacomo Calzolari and Alberto Franco Pozzolo

1. Introduction

That environmental sustainability should gradually become strictly interrelated to financial activities is a widespread and entirely accepted principle, pursued through financial regulation, supervision, and banks’ and financial institutions’ voluntary actions.

But it is not so obvious why this is the case. If markets were able to internalize environmental costs and risks fully, these should be adequately priced by financial institutions and banks. The allocation of credit and other financial resources would then reflect such costs and risks. And if there were, as there are market failures, these should be addressed by policy instruments targeted explicitly to reducing emissions, like carbon pricing or other fiscal tools, so that financial institutions could then face and respond to adequate pricing signals.

Moreover, by affecting the allocation of assets in terms of their environmental intensity, financial regulations also influence their risk mix. Polluting activities or activities potentially exposed to climate change face physical (environmental damage) and transitional (change in regulation) risks. But green assets are frequently based on new and untested technologies. Hence they are also risky. The ideal mix between these two types of risk should in principle be identified by the objective function of policy makers or social planners, not necessarily by financial regulators.

So, why is there a need for an environmentally-focused action in financial and banking markets? This is one of the two questions addressed in this issue of European Economy. The other one, is how this should and is being done, especially through regulatory and supervisory frameworks, voluntary actions and standards for measuring and disclosing climate and environmental risks.

As for the why, a simple argument is that climate-related risks could impair the ability of central banks to achieve their mandated objectives, for example because climate change and mitigation policies may affect inflation dynamics and also financial stability, as discussed by Campiglio and Lamperti in this issue. Consequently, central banks could directly target green financial instruments in their asset purchase actions.

At the same time, central banks, along with other mandated authorities, could affect the market behaviour of banks and financial institutions through regulatory and supervisory tools. Four other arguments support this type of action.

The first one is that environmentally stringent regulation for financial institutions is less politically costly to be put in place than fiscal instruments affecting the generality of businesses and consumers. Paradoxically, even though nowadays no political party could be elected without a platform explicitly addressing climate change, fiscal tools raising the prices of fossil fuels can give rise to massive political resistance and turmoil, see for example the uprising of the Gilets Jaunes movement in France following a fiscally induced slight increase in fuel prices. At the same time, an effective carbon taxation should be global and fully harmonized through border adjustments. In this respect, a coherent global policy alignment is difficult to implement and faces a lot of resistance, as shown by the recent, pretty generic commitments reached during the United Nation Conference on Climate Change, Cop 26 conference. These policies are necessary of course, but they are not there yet.

Financial institutions are easier to regulate. There is consensus on the need to reduce the riskiness of financial markets in itself, and on the fact that climate change raises high physical risks (e.g. environmental disasters) and transitional risks (e.g. changes in regulation and consequent stranded assets). In that respect, especially banks, have an issue of legacy stranded assets that regulators are bound to face, for example in fossil fuels. Investors are also increasingly sensitive to the pursuance of ESG objectives and are in favour of stringent environmental targets. The risks of investing in green technologies are certainly sizeable and frequently uncertain, but the pressure toward the environmental transition partly reduces the perception of such risks.

A second reason for targeting financial markets is that since fiscal tools are not yet (or are just partially) in place, or in the end they cannot be fully enforced, and consequently market prices do not adequately internalize environmental costs and risks, there is a need for a rapid action, which can more easily be taken by directly targeting financial markets. The mitigation of both physical and transitional risks in asset allocation can more effectively be achieved through financial regulation in the short/medium term. The following section of this editorial discusses this issue at length.

A third one, is that the financial effort required to achieve environmental targets and mitigate climate change is enormous and all resources must be mobilised towards this goal as soon as possible, pressing financial markets in this direction even beyond what would be achievable with mere fiscal incentives.

Fourth and finally, as discussed below, there are failures that cannot be targeted by fiscal instruments and directly pertain to financial markets and interact with pure environmentally induced market failures. For example, credit constraints induced by asymmetric information. Also, De Haas and Beyene et al. in this issue discuss at length how banks generally price environmental risks less than capital markets and how this is also related to the limited perception that depositors, in contrast to direct investors, have on the allocation of banks’ assets. The last part of this editorial will discuss the role of banks vs. capital markets in financing the environmental transition.

As for the how, several contributions in this issue discuss the regulatory and supervisory frameworks adopted or planned (Beyene et al., Mikkelsen et al. and Marullo Reedtz). These, in general, pertain to several domains. First the definition of shared criteria for the measurement and disclosure of the environmental risk, both concerning assets with implicit physical riskiness and those involving transitional costs. Second, the evaluation and inclusion of such risks by financial institutions in their risk appetite frameworks and in supervisory actions and stress tests and the provision by supervisors of clear guidelines. Third, a balanced use of regulatory tools like capital requirements, on the one hand to favour asset allocation towards sustainable investments and, on the other hand, to reduce the risk of rapid divestment from established fuel intensive assets.

The issue focuses especially on the actions of EU institutions, initially triggered by the EU Commission Action Plan on Financing Sustainable Growth in March 2018 and which involves the European Central Bank (ECB), the European Banking Authority (EBA).

Also important are frameworks which imply a voluntary action by financial institutions. In particular, the Task Force on Climate-related Financial Disclosures (TCFD) was established by the Financial Stability Board (FSB) for climate related disclosures and the Net-Zero Banking alliance, which now involves all major financial players. There is an open issue of how far these voluntary arrangements should become compulsory in the longer term.

In what follows, we develop the arguments for why financial regulation should address environmental issues and discuss the different position of banks and capital markets as recipients of such regulatory frameworks.

2. Why financial regulation?

Problems of sustainability of economic decisions are inherent problems of adverse external effects: “the negative effect of production, consumption, or other economic decisions on another person or party, which is not specified as a liability in a contract” (Core, 2017) and therefore is not taken into consideration by a selfish profit or utility maximizing economic agent.

Consider the most debated one: emissions of greenhouse gases causing global warming (Stern and Stern, 2007). Like any other type of pollution, it is a negative externality. Negative externalities have been thoroughly analysed in the economic literature. Two leading solutions have been proposed: limits to production and taxation. Indeed, the most obvious solution in front of a polluter is to force him to stop. But this is an oversimplification because the social costs of completely halting the activities of a polluter can often be higher than the benefits (if Pfizer were marginally polluting to produce vaccines, we would probably be unwilling to force its closure). Welfare maximization requires comparing costs and benefits and set any quantitative limit to production at the level that equates the marginal social costs of production with the marginal benefits. However, this is more easily said than done, especially when producers are in large numbers – coordination on quantity limitations is complex among countries, let aside among single firms – and when the adverse external effects are not instantaneous but delayed in time, as in the case of global warming.

Fixing precise limitations to any activity that generates external effects and imposing them on each economic agent is clearly infeasible. A first option to circumvent this problem is cap and trade policies, i.e. to define a measure of the negative external effect (e.g., tonne of carbon emissions) and price them (see Campiglio and Lamperti in this issue). Once this is done, these policies can go a long way in solving the coordination problems of quantity limitations by allowing firms to trade the right to emit among themselves. Although the decision on how to initially allocate these rights is not obvious, the outcome is efficient, because those firms who incur the lower costs to reduce emissions have the higher incentive to do so. At the same time, the total amount of rights to emit that are granted allows to control the aggregate level of emissions.

Taxation is the alternative to impose quantitative limits, directly or through cap-and-trade policies. Set a Pigouvian tax equal to the marginal external cost – the difference between the (possibly delayed) marginal social cost and the private social cost – and profit maximizing firms will automatically choose the socially optimal production level. Taxation allows to force economic agents to internalize the external effect of their actions, leading to an optimal aggregate level of carbon emissions. According to this view, the optimal strategy to limit greenhouse gas emissions – or any other external effect in production or consumption – is to levy a Pigouvian tax. As such, there is no need to adopt indirect strategies, such as regulations in the financial markets making the cost of funding dependent on how “green” an investment is, so as to “reorient capital flows towards sustainable investment in order to achieve sustainable and inclusive growth” (EU Commission, 2018).

However, there are at least two main problems with this prescription. One is the interaction of the external effects with other features of the economic system, such as imperfections in financial markets. The other is the evaluation of the joint riskiness of both the impact of the negative external effect (e.g., global warming) and the actions addressing it.

The case of imperfections in the financial markets is relatively straightforward. Consider two firms that must decide whether to invest in adopting a greener production technology. To simplify the analysis, assume for the moment that such technology is readily available, and its cost and benefits are known. One incurs lower costs to adapt to the new technology, but due to credit constraints, it faces high borrowing costs and prefers to renounce investing. The other firm has low borrowing costs, but it is also unwilling to invest since it faces high adaptation costs. Taxing carbon emissions would increase the costs for both firms if they did not invest in acquiring the new technology. The firm facing high adaptation costs may be forced to make the investment, despite the higher adaptation costs, while the credit constrained one may still find unprofitable to invest. An alternative policy, introducing incentives to finance green investments, would instead reduce the borrowing costs for the credit constrained firm, making it more likely to invest in green technology. For reasonable ranges of the differences between the costs of adopting the new technology and the borrowing costs for the two firms, it is possible that financial market regulation allows to achieve a lower level of emissions with the same impact on production. Regulations favoring investments in greener productions or technologies may thus be more effective than directly taxing emissions.

The issue of riskiness is two-faceted (on this theme, see also Campiglio and Lamperti in this issue). On the one side, there is a legacy problem: economic activities started when the global warming problem was underestimated (and therefore Pigouvian taxes were not introduced) can suffer significant losses, causing a surge in the riskiness of the existing portfolio of investments. On the other side, there is a perspective problem because the development and adoption of environmentally sustainable technologies require large investments, typically involving a high riskiness of both private and social returns.

The consequences of the permanent increase in average world temperature caused by greenhouse gas emissions are the object of an intense debate among scientists. Their economic effects are also the focus of a growing body of research (Cruz Álvarez and Rossi-Hansberg, 2021). It seems unquestionable that exceptional risks loom ahead.

From a portfolio management perspective, the problem is whether these risks are priced correctly by investors, particularly by financial intermediaries. If global warming led to extreme events causing radical changes in the economic system – from severe weather conditions to substantial relocations of economic activities – the value of assets held by financial intermediaries would collapse. If provisioning to face these risks was insufficient, a financial crisis would likely unfold. As already seen with the global financial crisis of 2007-2008, this may cause monetary policy problems, calling for radical interventions by central banks.

Provisions may be inadequate for two main reasons. First, investors may be unable to collect and process the vast amount of information required for a sound assessment of the risks caused by global warming. A possible solution would then be to elaborate and provide information on the risks caused by global warming to economic activities, to help investors accounting for their effects in their decisions. As argued by Degryse et al. in this issue, this is already happening, at least in part.

Second, the investors and especially financial intermediaries may not have the right incentives to set aside adequate provisions if they believe that the effects of global warming will be so pervasive to require in any case an intervention by public authorities. We can dub this as a “too-pervasive-to-face” problem. The obvious response to such a scenario is to introduce specific regulations of financial markets forcing intermediaries to cover the risks caused by global warming adequately.

In principles, the rationale for such interventions is not to sustain the funding of investments in greener technologies but to cover the risks caused by greenhouse gas emissions. In fact, such risks may even be unrelated to the production of negative external effects, depending only on how much the existing economic activities are exposed to the consequences of such effects. In practice, requiring higher provisions to cover the risks of the activities more severely affected by global warming will also impact on the allocation of portfolios towards greener investments. First, corporations such as airlines both produce negative external effects and are affected by events extreme weather events caused by global warming. Second, the likely introduction of a Pigouvian tax on polluting corporations is itself a risk that regulations will ask to cover, making it less profitable to conduct these economic activities.

The second type of risk is related to developing and adopting “green” technologies, which is an effective alternative to reducing the level of production in industries that negatively impact the environment. The question is how much shall we invest in this endeavour? Welfare maximization requires comparing the cost of developing and adopting these technologies with the benefit that they guarantee in reducing the external costs. However, both costs and the benefits entail significant risks, which are difficult to evaluate, making it difficult to find the funding required for such investments (as in the well-known cases of R&D financing) especially by financiers like banks and traditional investment funds. In complete and perfectly working financial markets, a Pigouvian tax increases the costs of production, providing an incentive to reduce its levels and, therefore, those of greenhouse gas emissions.

However, Pigouvain taxation may be more challenging to organise, and it can create an additional layer of uncertainty, related to its application through time, relative to a financial regulation that favours financing the development and adoption of greener technologies. As discussed in more detail in the next session, differences in risk aversion across financiers can also impact the adoption and development of green technologies.

Banks vs. markets

Finance and investments are necessary ingredients for a swift green transition. This observation naturally begs the question about the most effective ways to finance the investments that the green transition requires. This question has no unique answer, as it depends on the characteristics of the investing firms and the type of investments. The heterogeneity of firms and investments relevant to the green transition explains some of the mixed results identified in the academic literature and discussed in the articles in this issue of European Economy. We identify three critical factors for financing investments in general and the green transition in particular.

First, to understand the role of finance in the green transition, one needs to move away from the ideal world of the Modigliani and Miller theorem, where the source of finance does not matter for firms (value). In a realistic realm, the “pecking order theory” for finance (Myers and Majluf, 1984, for its adverse selection incarnation and Jensen and Meckling, 1976, for the cost-of-agency one) provides a first helpful step in understanding how firms finance different investments. Ample empirical evidence shows that to address issues of asymmetric information and reduce the cost of financing, firms first rely on retained earnings as the cheapest source of funds and then on external finance, first debt and then equity, with increasing financing costs that reflect the higher associated risk for the external parties.

A second relevant element is that the mentioned hierarchy of financing sources adapts to the “financial growth cycle” of the investing firm and its characteristics, such as size and actual and prospective growth. For example, small start-ups with high growth potential and high risk very often rely on venture capital and private equity.

A third key point is the nature of the investments needed for the green transition. Simplifying and relying on the articles on the present issues of the European Economy, we can identify two types of investment: one aiming at drastic innovations and another helping polluting firms start coping with and reducing their emissions using existing technologies. These types of investments are different. The former is much riskier as it aims at delivering new technologies with a long investment span. The latter is less so and could be seen as “retrofitting” or adapting existing production activities with abatement technologies. Also, the output of the former type of investment is typically intangible, such as with intellectual property rights and trade secrets. Instead, that of the latter is incorporated in production assets, such as renewable energy generation. As we further explore below, these critical differences in risk, investment span, and intangibility have material implications for funding different parts of the green transition.

Combining all these factors, the hierarchy in cost of finance, the characteristics of the investing firms, and the types of investments offers a rich picture to understand how and to what extent sustainable finance can contribute to the green transition. In particular, we are interested in understanding which type of finance is better suited to provide funds for the green transition. Given our three key elements, it is clear that the answer to this question depends on the possible matches between the alternatives, in particular (i) the source of funding, e.g., banks or financial markets, (ii) the characteristics of the investing firm, e.g., established firms or high-growth potential start-ups, and (iii) the type of green investment, e.g., new technologies or existing abatement technologies. The possible matches of the factors (i)-(iii) provide 2x2x2 combinations, some of which are more apt to finance the green transition than others.

In particular, in light of these observations, banks may face relevant issues in financing green investments when associated with certain matches combining points (i)-(iii) discussed above. A first specific problem often mentioned is that the green transition operates in a pre-existing environment where banks provide funds to firms, typically relying on debt contracts and associated collaterals. The green transition is intended to shift activities from pre-existing ones to more environmentally friendly ones. This transition tends to reduce the value of pre-existing technologies and associated assets that banks hold in their accounts. Banks may thus prefer not to contribute with their actions that may accelerate this devaluation of assets and collateral related to dirtier technologies. This observation, also discussed in Degryse et al. and De Haas in this Issue of the European Economy is reminiscent of what we have observed with the Non-Performing-Loans(NPL) crisis a few years ago, where banks avoided for quite some time the write-down of bad debts (see the European Economy 2017 issue n. 1). Although unilaterally, the fear of the risk of an adverse market reaction was understandable, collectively, keeping NPL in banks’ balances contributed to a general instability of the whole sector and required prompt policy interventions.

The problem of pre-existing lending to non-clean investments shares some similarities with NPL and some significant differences. In particular, although NPL banks had clear individual incentives to keep inflated asset values, with the green transition, it is difficult to imagine that each bank individually anticipates and fears the devaluation effects in legacy portfolios and hence perceives the risk of the transition of its lending to innovative green technologies. For example, Beyene et al. (2021) show that banks continue to underprice the risk of asset devaluation for traditional investment due to the green transition, which seems odd with a bank’ strategy of limiting entry green innovative firms with credit rationing. Relatedly, other banks’ characteristics contribute to their attitude towards green investment. Since banks tend to have a shorter investment time horizon than equity markets, they consequently tend to care less for possible future devaluation of assets associated with a high-carbon footprint. In this respect, capital markets seem more apt for prompt corrective action incorporating the increasing environmental risks.

Traditional banks also perceive less pressure to adapt to changing needs and preferences of ultimate funders, in their case depositors, as compared with investment funds. Although attention toward cleaner activities and investments is increasing, traditional banks offer a bundle of many different services to depositors, which may dilute the perception by depositors of the greenness of banks’ asset allocation. Relatedly, the actual exposure of banks towards polluting activities and or the fossil fuel sector is not readily available to banks depositors, as emphasized in Beyene, Delis, and Ongena in this Issue of European Economy. On the contrary, when investors patronize investment funds, the link between the funded projects and the investors’ preferences is more direct and visible. Relatedly, the universal-service characteristic of traditional banks makes it more difficult for banks’ management to keep track of the specific technologies adopted by the firms they lend to. This limited knowledge may ultimately weaken banks’ ability to invest in environmental-friendly innovations.

The different technologies relevant to the green transition can more or less fit what banks can effectively offer and handle. Banks can play a significant role in funding transition investments that allow firms to “retrofit” and adapt their production process towards cleaner approaches. In these cases, borrowers’ traditional assets can offer collaterals that banks can rely on for lending. Instead, financing the developments of drastic innovations for new green technologies may be problematic for banks because these types of innovations typically produce intangible outputs such as patents and trade secrets. As with any type of R&D intense investments, when the outcomes of the investments are intangible and thus non-pledgeable, banks can provide limited funding sources, and capital markets are more apt to address these environments. This is also convincingly emphasized by the papers of De Haas and Degryse et al. on this Issue of European Economy, which illustrate that green patented innovations expand faster in countries where equity finance is more prominent compared with bank lending. This observation is particularly relevant for bank-centric Europe that should channel as much as possible equity funding towards environmental innovations, possibly also rebalancing tax biases in favour of equity rather than debt.

How effective are banks dealing with polluting firms? There is some evidence that banks can price loans incorporating environmental impact. Chen et al. (2021) show that firms that emit more pay higher interest rates than banks, primarily when emissions are associated with more risky borrowers and weak governance. However, the question is whether banks are better able than capital markets to price environmental risks correctly. As discussed by De Haas in this Issue of European Economy, access to credit per-se favours investment in cleaner technologies, although the most relevant factor seems instead the quality and attitude of firms’ management towards environmental issues. Moreover, since banks continue to underprice the risk of asset devaluation for traditional investment, firms relying on carbon-heavy technologies are currently moving away from bonds to bank credit, as documented by Beyene et al. (2021b).

Interestingly, both De Haas and Degryse et al. in this Issue of European Economy have shown that the best outcomes from the credit markets obtain when “green-meets-green,” when banks explicitly commit to green lending match with environmental conscious borrowers that effectively disclose their attitude. In these cases, mutual commitment and disclosure on the two sides of the credit market allow for a cheaper lending cost. An immediate policy implication seems thus that of facilitating credible disclosure of the environmental attitude of both sides of the credit market.

Overall, banks’ difficulty in correctly pricing environmental risks combines several elements, as argued above. The articles in this issue of European Economy provide several policy actions that could redress this problem. Essential in this direction will be improving transparency and disclosure requirements about actual exposure to polluting industries and environmental risks. Moving from a voluntary approach (prone to manipulation and cherry-picking, as shown in Bingler et al. 2021) towards mandatory requirements, such as recently announced by New Zealand, the United Kingdom, and Switzerland seems a fundamental step.

3. Conclusions

In principle, Pigouvian taxation could fully internalize environmental costs and risks, making it useless to introduce ad hoc financial regulations (see Cochrane, 2021, for a view along these lines). But to attain a more sustainable equilibrium in the presence of other market failures, policy interventions in the financial markets can be an effective complementary tool to Pigouvian taxation.

Two main types of interventions have been proposed and are being put in place (see, in particular, Marullo Reedtz and Mikklesen et al. in this issue for a comprehensive analysis). First, the provision of rigorous and standardized information to investors, through the definition of criteria for the measurement and disclosure of environmental risks (e.g., the Taxonomy Regulation of the EU, the Sustainable Finance Disclosure Regulation, the Regulation on European green bonds), and the requirement that large public-interest entities publicly report on sustainability issues (e.g., Directive 2014/95/EU). Second, the explicit inclusion of environmental risks in the bank supervisory framework, including capital requirements and stress tests (e.g., EBA’s Implementing Technical Standards on Pillar 3 disclosures on ESG risks), and in central bank’s analyses (e.g., ECB’s Guide on climate-related and environmental risks).

The ample set of policies proposed in the financial sector will be paralleled by more traditional interventions addressing the effect of negative externalities through taxation and quantitative limitations. These will also impact investment returns (see also the discussion in Giovannini and Tamburrini, in this issue). Overall, the impact on the entire financial industry will be pervasive, affecting the choices and performance of banks, investment funds, insurance companies, and retail investors.

A natural set of questions thus arises. What objective function is driving this process? Who has chosen this objective function? Who is controlling that, when enacted simultaneously, the selected policies point in the right direction to achieve the desired goals?

The answer to the first question is apparently easy: the objective of all proposed policies is to internalize the adverse external effects that make individual choices unsustainable. But this goal requires a precise quantification of the social surplus to be maximized, a daunting task in any welfare analysis. In the absence of a unique solution, the objective function to be maximized should be chosen by citizens, following a democratic process. This observation leads to the answer to the second question that elected governments should determine the objective function to be maximized. While it may be largely agreed that the mandate of financial regulatory authorities reflects the government’s will for financial stability and the general working of financial markets, that such a mandate also reflects government choices on environmental issues is not so obvious. This may call for stricter directives from governments to financial authorities on environmental issues so as to enhance their accountability.

The last question has apparently no answer. Different bodies define different sets of rules, often with a large degree of autonomy. But a body or a framework coordinating the different policies and controlling that their decisions are not contrasting is absent. Given the large number of proposed and implemented interventions, the risk of a lack of coordination is substantial. This calls for a coordination table on environmental issues among all interested bodies. This framework should be set at the European level. In addition, given the global scope of environmental issues, it should be organized at the world level (see also Panetta, 2021).

References

Beyene, W., Delis, M., and Ongena, S. (2021a). Disclosure of Bank Fossil Fuel Exposures. European Economy – Banks, Regulation and the Real Sector, this issue.

Beyene, W., de Greiff, K., Delis, M., and Ongena, S. (2021b). Too-Big-To-Strand: Bond to Bank Substitution in the Transition to a Low-carbon Economy, Swiss Finance Institute, Mimeo.

Bingler, J. A., Kraus, M., and Leippold, M. (2021). Cheap Talk and Cherry-Picking: What ClimateBert Has to Say on Corporate Climate Risk Disclosures, University of Zürich, Mimeo.

Bowles, S., Carlin, W. and Stevens, M. (2017). ‘Market, efficiency, and public policy’. Unit 12 in The CORE team, The Economy. Available at: https://www.core-econ.org. [Accessed on April 17th, 2022].

Campliglio, E., and Lamperti, F. (2021). Sustainable finance policy-making: Why and how. European Economy – Banks, Regulation and the Real Sector, this issue.

Chen, I-Ju, Iftekhar Hasan, Chih-Yung Lin, Tra Ngoc Vy Nguyen, 2021, Do Banks Value Borrowers’ Environmental Record? Evidence from Financial Contracts, Working paper.

Cochrane, J.H. (2021). Testimony of John H. Cochrane to US Senate Committee on Banking, Housing, and Urban Affairs. Available at: https://www.banking.senate.gov/download/cochrane-testimony- [Accessed on April 17th, 2022].

The CORE Team (2017). The Economy: Economics for a changing World, Oxford University Press.

Cruz Álvarez, J.L. and Rossi-Hansberg, E. (2021). The Economic Geography of Global Warming. NBER Working Paper Series, No. 28466. Cambridge, MA: National Bureau of Economic Research.

De Haas, R. (2021). Finance and firms on the road to net zero. European Economy – Banks, Regulation and the Real Sector, this issue.

Degryse, H., Goncharenko, R., Theunisz, C., and Vadasz, T. (2021). The green transition and bank financing. European Economy – Banks, Regulation and the Real Sector, this issue.

European Commission (2018). The Action Plan for Financing Sustainable Growth.

Giovannini, A., and Tamburrini, F. (2021), Sustainable Finance: Three Questions in Search of an Answer. European Economy – Banks, Regulation and the Real Sector, this issue.

Jensen, M.C., and Meckling, W.H. (1976). Theory of the firm: Managerial behavior, agency costs and ownership structure. Journal of Financial Economics, 3: 305-360.

Mikkelsen, D., Viscardi, S., Montes, M., and De Amicis, F.P. (2021). Climate change regulation and supervision in Europe and implications for commercial banks. European Economy – Banks, Regulation and the real Sector, this issue.

Marullo Reedtz, P. (2021). Financing the environmental transition in Europe. European Economy – Banks, Regulation and the real Sector, this issue.

Myers, S.C., and Majluf, N.S. (2021). Corporate financing and investment decisions when firms have information that investors do not have. Journal of Financial Economics, 13: 187-221.

Panetta, F. (2021). A Global Accord for Sustainable Finance. Available at: https://www.project-syndicate.org/commentary/sustainable-finance-global-taxonomy-agreement-by-fabio-panetta-2021-05 [Accessed on April 17th, 2022].

Stern, N., and Stern, N.H. (2007). The economics of climate change: the Stern review. Cambridge University Press.

Filed Under: 2021.2, From the Editorial Desk

Sustainable Finance Policy-Making: Why and How

April 20, 2022 by Emanuele Campiglio and Francesco Lamperti

Authors

Emanuele Campiglio[1]University of Bologna. and Francesco Lamperti[2]Scuola Superiore Sant’Anna (Pisa) and RFF-CMCC European Institute on Economics and the Environment (EIEE, Milano).

 

Why should central banks and financial supervisors worry about climate change and decarbonisation? And how are they supposed to act upon them? These questions have been asked many times in recent years, but have yet to receive a definitive answer.

The main institutional answer given so far – at least in Europe and similar jurisdictions – has been based on the possibility that climate change or the low-carbon transition might affect the ability of central banks and supervisors to achieve their mandated primary objectives, such as price and financial stability (Schnabel, 2021; Semieniuk et al., 2021). If these climate-related risks were found to be material, stronger policy action would be justified.

But how are we supposed to find proof of the materiality of climate-related risks? At the moment, deep knowledge gaps remain in all the necessary ingredients: i) abundant and granular data; ii) methods to analyse and understand empirical evidence; and iii) reliable modelling methods to explore future scenarios. In the face of climate change and the urgency of decarbonising the global economy, obtaining incontrovertible results on risk materiality, if possible at all, might take too much time.

Even without proof, there are a number of things policy-makers can do and, to some extent, are already doing. One is to put a price on carbon; governments should attend to that. Another is to expand the information set available to market participants, to allow them to price risks correctly. Central banks and supervisors can play a key role in this dimension, supporting the development of risk assessment methods and pushing financial institutions to disclose their exposure to climate-related risks. Both these policies have a theoretical backing in the idea of correcting specific ‘market failures’, i.e. the environmental externality and imperfect information.

Will this be enough? It’s unlikely. There are several political obstacles to carbon pricing, and many additional failures affect the functioning of markets, especially financial ones. Two main alternative options can be considered. The first option is to lower the level of sophistication of mechanisms supporting the implementation of unconventional monetary/financial policies addressing climate risks. Empirical evidence shows that, in the face of radical uncertainty about the future, policy-making decisions based on `fast and frugal’ rules of thumb can outperform more sophisticated decision-making rules trying to capture the ineffably complex dynamics of the global economy. The second option is to explicitly modify the institutional structure to ensure more effective climate action, e.g., changing the mandates of central banks and supervisors, or creating additional delegations to independent institutions. Both options might require bending and adapting the current institutional boundaries, which comes with some risks to be accounted for.

In the remainder of the article, we discuss these points more in detail. We start by presenting the current conceptual and institutional justifications for existing sustainable finance policies. We then discuss their limitations in ensuring effective climate action and explore alternative strategies going beyond existing institutional frameworks. We conclude by inviting to a deeper analysis on the potential benefits and risks of these institutional options.

 

Sustainable finance policies: a recap

The pivotal role of finance in supporting an orderly and rapid decarbonisation process (and thus the mitigation of climate impacts) has been increasingly recognized by the international community. First, the discovery, commercialization, deployment and diffusion of low-carbon technologies require adequate financial investments in the form of bank loans, debt and equity finance. Second, the financial risks materialising during the transition (e.g. an excessively rapid devaluation of carbon-intensive assets, or a ‘green’ bubble) need to be safely absorbed, minimising financial and economic instability.

Several ‘market failures’ might prevent financial market actors to autonomously align along a technological transition compatible with climate stability (e.g. maintaining temperatures below 1.5-2°C, as stipulated by the Paris Agreement). If this is the case, adequate policy guidance is needed. However, policy action is even harder than usual in this context, as financial policy-making and regulation functions are often in the hands of delegated authorities, i.e. independent or semi-independent institutions that have received a mandate to achieve specific and limited objectives. This is especially the case of central banks, which in many jurisdictions enjoy a high degree of independence in pursuing price stability (the quintessential central bank objective), macroprudential stability (especially after the 2007-08 global financial crisis), and whatever other goal governments have opted to delegate to them.

Nonetheless, we have experienced an increasingly strong presence of delegated authorities in the climate debate. Starting with the ‘Tragedy of the horizon’ speech of the Governor of the Bank of England (Carney, 2015), central banks and financial supervisors have played a key role in mainstreaming sustainable finance, e.g. with the creation of the Task-force on Climate-related Financial Disclosures (TCFD, 2017) and supporting the work of the European High-Level Expert Group on sustainable finance (EU HLEG, 2017). Further, the creation of the Network for Greening the Financial System (NGFS) in 2017 reflected the desire for an intensified international cooperation, in the attempt to strengthen the global response required to meet the goals of the Paris agreement.

Several delegated authorities have nudged or required companies and financial intermediaries to ‘stress-test’ their portfolio against climate-related risks and disclose the results, or have run system-wide climate stress-tests of their banking and financial systems (Baudino and Svoronos, 2021; ECB, 2022; Vermeulen et al., 2018). Other delegated authorities, especially in emerging economies, have gone further, employing their policy toolkit to actively promote green and low-carbon investments, such as differentiated reserve and capital requirements depending on the greenness of bank lending, favourable refinancing lines and green credit quotas (Campiglio et al., 2018; D’Orazio, 2022) .

But why are central banks and supervisors acting on climate in the first place? And what determines their degree of engagement?

 

Climate-related risks might affect price and financial stability

A first argument for action builds on the possibility that climate-related risks could affect the ability of central banks and others’ financial authorities to achieve their mandated objectives (price stability, financial stability, and others).

As emphasised by Schnabel (2021), there are three reasons for which climate-related risks might impair central banks’ effectiveness at managing inflation. First, the transmission of central banks’ monetary policy measures to the financing conditions faced by households and firms are likely to be affected by climate-induced losses. Losses from materialising physical risks or asset stranding (such as fossil reserves that will remain unextracted as the world decarbonises) could weigh on financial institutions’ balance sheets, reducing the flow of credit to the real economy and impairing the credit channel (Lamperti et al., 2019). Second, climate-related risks (e.g., productivity losses induced by physical risks, or diversion of resources from more productive activities, such as R&D and education, to climate adaptation) might reduce the real equilibrium interest rate, pushing central banks closer to the boundaries of conventional monetary policy (Boneva et al., 2021). Third, both climate change and mitigation policies can have a direct impact on inflation dynamics by amplifying business cycles fluctuations and uncertainty, thereby requiring a greater interventionism through conventional channels.

Climate-related risks could also affect the stability of financial systems (Semieniuk et al., 2021). While the precise nature of risks and transmission channels is different between climate impacts and a low-carbon transition, they exhibit some key shared features. Non-financial firms could be affected by both a change in costs or revenues leading to a decline in profits (e.g. due to a carbon tax or climate-induced supply chain disruptions) and balance sheet losses (e.g. destruction of physical assets due to extreme weather events). These costs could then propagate to financial institutions in two main ways: i) firms defaulting on their bank loans; ii) a drop in the valuation of firms’ financial assets. Exacerbated by production and financial network effects (Cahen-Fourot et al., 2021), large enough initial shocks could eventually have systemic implications, causing a macro-financial crisis — what Bolton et al. (2020) call a ‘Green Swan’. An overvaluation of green assets leading to the burst of a bubble is also a possible mechanism of transition-related financial disruption.

 

Can we ‘prove’ the materiality of climate-related risks?

So far, we have claimed that climate change and the low-carbon transition might affect price and financial stability. Policy-makers and academia have started developing theoretical conceptual frameworks describing what a ‘disorderly transition’ or a ‘Climate Minsky moment’ could look like (NGFS, 2019). However, we still don’t know to what extent these scenarios are actual possibilities we should worry about, nor do we have a reliable assessment of the economic and financial implications of climate-related risks. In jurisdictions characterised by the presence of independent authorities with clear and limited objectives, the absence of reliable proof of the materiality of climate-related risks represents a crucial obstacle to policy action.

What would we need to reliably assess the materiality of climate-related risks and justify action? Three elements are key: i) abundant, harmonised and sufficiently granular data; ii) empirical methods to analyse and interpret the data; and iii) modelling methodologies to examine future scenarios in all their dynamic complexity. Unfortunately, several key knowledge gaps currently exist in all three dimensions.

First, data is often absent, scattered or not harmonised. Several projects have been set up to collect and analyse asset- and firm-level information, e.g. for coal/gas plants, housing properties, and infrastructure (see for instance the GeoAsset project). However, more work is needed to provide an integrated perspective across countries and sectors. In addition, clear large-scale data maps of real-financial linkages are often absent and, when available, they typically do not encompass sufficient spatial detail to quantify physical risks.

Second, the empirical analysis of the data is also in its infancy. The analysis of exposures is becoming common, both for what concerns physical assets (Tong et al., 2019) and financial assets (Giuzio et al., 2019). However, the analytical and quantitative power of such tests is likely to remain limited, given their static nature. It is also hard to link exposure data to the probabilities of individual counterparties defaulting due to climate-related drivers that have no historical precedents. In addition to exposure data, it would be key to have a better understanding of climate-related expectations and beliefs of economic agents, as these would contribute to defining the response of the system to shocks. Asset pricing methods can be used to study the extent to which climate-related risks are already internalised by investors. Bolton and Kacperczyk (2021), for instance, find evidence of positive carbon risk premia in recent years, suggesting that investors increasingly request compensation for the potential costs that mitigation efforts would create for carbon-intensive firms. Alternative approaches to capturing climate-related ‘sentiments’ include using text analysis methods to study communications — such as social media posts, speeches, newspaper articles (see for instance Engle et al., 2020) — and running surveys of investors to elicit their opinions and beliefs (e.g. Krueger et al., 2020). However, much more work is still needed in this direction.

Third, one should feed the data and estimated parameters to adequate models enabling a dynamic exploration of possible futures. Several features would need to be present for a model to be able to fully grasp the complexity of possible macro-financial and transition patterns, including: (i) a multi-sectoral perspective, including inter-industry exchange of intermediate inputs and supply chains; (ii) multiple technologies with different physical, financial and sustainability characteristics; iii) clear links between the real and financial parts of the model, including mechanisms of portfolio choice and credit provision; iv) mechanisms to incorporate propagation of shocks across both production and financial networks; v) a realistic representation of dynamic human behaviour, including its irrational and socially-determined dimensions; vi) a way to incorporate uncertainty and its impacts on decision-making. Unfortunately, although not surprisingly, the assessment of climate-related risks is currently being carried out employing models that generally do not exhibit all of the dimensions above (Baudino and Svoronos, 2021; ECB, 2022), though some alternatives are gradually emerging (see for instance Lamperti et al., 2021, 2018). More in general, models are by definition aimed at reducing real-world complexity in order to understand its key mechanisms. This requires making a number of limiting assumptions on human behaviour and the functioning of economic systems, which in turn makes all models susceptible to criticism and non-acceptance. In other words, the perfect model, accepted by everyone, might never come.

Considering all of the above, a question ensues: what happens if a solid and incontrovertible proof of the materiality of climate-related financial risks never materialises? We discuss two main strategies in the coming sections: (i) find ways to act within the existing institutional framework; (ii) adopt policy choices that bend or modify the institutional framework.

 

Strategy 1: act within the existing institutional framework

A first strategy is to accept the limitations imposed by the current institutional framework and do whatever is already allowable within it. Luckily, there are plenty of options available and, to some extent, already pursued.

The most prominent policy option is of course to put a price on carbon, either via taxes or the introduction of a market of carbon allowances (Baranzini et al., 2017). In simple economic terms, this is directed at addressing a market failure, i.e. the environmental externality. Since many environmental goods and services (including climate stability) do not have a market price, private economic agents are able to keep the benefits of polluting (i.e. production and associated profits) for themselves, while socialising its costs. This constitutes a strong disincentive to shift towards cleaner production technologies. If, however, the externality was to be internalised via policy (e.g. a carbon tax), consumers would have the incentive to move towards green products and firms would be more inclined to innovate their technologies and substitute high-carbon for low-carbon intermediate inputs. In absence of additional market failures, this should also convince financial institutions to support low-carbon activities.

Of course, fiscal policy is not really a function under the control of central banks or financial supervisors, but rather of governments and finance ministries. So, unless there is a modification of the current institutional framework (e.g. via a carbon central bank, see last section), delegated authorities’ only role in this regard is to remind that carbon pricing is necessary and urgent, via both research and institutional pressure (e.g. speeches). However, this does not make central banks powerless. Indeed, there are a variety of possible climate finance policies, whose scope will depend on the underlying institutional framework. In high-income western economies like the European Union, where delegated objectives are narrow, at least two categories of initiatives can be launched.

First, central banks and financial institutions have a central role to play in supporting the scientific community in the assessment of climate-related risks. Not only they hold the largest and most detailed data sources about financial and non-financial firms’ transactions; they also have a long tradition in developing macroeconomic models. These can offer insights on how business cycles are affected by both credit and asset market dynamics, including cases where assets’ values go burst (e.g. housing market models) and financial flows need moving from the banking sector to the real economy. In addition, thanks to their supervision activities, they can retrieve the sectoral and geographical exposure of banks and institutional investors. The expertise and data held by statistical and research departments within central banks are highly complementary to the knowledge stock on the effects of emission mitigation pathways and physical hazards. The question is how this information can be used effectively.

Second, central banks and financial regulators can increase information available to markets. This would reduce the existence of an information asymmetry failure. Banks and financial institutions face difficulties in inferring the exposure of a counterpart to transition risks and physical events. Central banks can develop forward-looking models of risk evaluation to account for climate and transition futures. If all information was available, in principle, financial firms would allocate credit more efficiently and effectively pricing climate-related risks. However, if this is not possible, distortions will emerge. The presence of deep uncertainties, as discussed above, is likely to make this process exceptionally hard or long, while evidence suggests that climate change is accelerating and carbon budgets to meet ambitious mitigation are rapidly depleting.

 

Will this be enough?

It is hard to know whether the initiatives outlined above, if implemented in a strong and credible manner, could provide a sufficient push to rapidly decarbonise the economic system. What we can certainly notice is that, at the moment, they are not fully implemented.

Carbon pricing initiatives have been multiplying and strengthening in recent years (World Bank, 2021). The EU Emission Trading Scheme, after long years of disappointment, has started to deliver strong carbon price signals, and the launch of Chinese national market of permits promises to be a further important step in the right direction. However, in general, recent evidence signals that carbon pricing is far more discussed in the academic debate than it is used in practice (Peñasco et al., 2021). This is due, at least partially, to its relatively low political acceptability and the dependence of policy action to the electoral cycle. Further, carbon pricing is complicated by three factors. First, the transition will come at some cost, at least for certain countries, sectors and firms; and the cost will be itself an outcome of how well is the policy effort carried out (i.e. an abrupt climate policy might trigger macro-financial disruptions). Second, fundamental uncertainty renders any calculation of the desirable carbon price questionable, which makes it difficult to credibly commit to a specific price path. Third, carbon pricing can be successful in reshaping economic decisions and financial flows only if markets work well. Unfortunately, this is hardly the case (Stern et al., 2021). Indeed, markets are prone to frictions, multiple equilibria, volatility and excessive market power, suggesting that price signals will hardly be sufficient to manage climate-related risks, and that carbon pricing should be considered as part of a much wider policy spectrum.

The informational policies mentioned in the previous section, aimed at assessing and disclosing climate-related financial risks, also have important limitations. First and foremost, the result that novel information is adequately reflected in financial prices follows from the demanding “efficient market hypothesis”. Beyond a number of historical failures of such hypothesis, recent evidence from a survey of institutional investors, whose portfolio is characterized by long maturities compatible with the scales of climate risks, rejects the view that additional and more precise information of climate-related risks can suffice to align their investment strategies (Ameli et al., 2021, 2020). Further, collecting information about climate risks and exposure of individual counterparts, as well as formalizing harmonized disclosure procedures aimed at generating reliable taxonomies and benchmarks may require time that would further delay markets’ reaction.

Considering these limitations and obstacles to implementation, it appears wise to explore additional and alternative policy options, even if these require some modification to the existing distribution of institutional responsibilities and functions.

 

Strategy 2: go beyond existing institutional framework

Going beyond what the current institutional framework allows is, of course, possible. Institutions are social constructs and they change as societies change. Indeed, current institutional frameworks are different from the ones of the past and evolved following changing societal needs. For what concerns central banks, the most recent paradigmatic shift has been the movement to central bank independence in a large number of countries during the 1990s, often accompanied by a focus on inflation targeting via interest rate manipulation (Vonessen et al., 2020). This constituted a significant change with respect to the traditional role central banks used to play throughout history.

To modify the existing institutional framework in an orderly and effective manner, three main ingredients are necessary. First, we need a theoretical justification for institutional change. This can be provided either by employing a conceptual framework centred around the concept of market failures or by invoking a precautionary approach in the face of deep uncertainty (Chenet et al., 2021). In either case, a theoretical justification for action is possible, even if not entirely present at the moment. Concerning failures, markets (including financial ones) are ripe with them, including the inability of individuals to understand complexity and their myopic and irrational behaviour. Credit markets may not be willing to provide the necessary liquidity to low-carbon firms, even in the presence of the ‘right’ prices (Campiglio, 2016). Alternatively, another argument supporting the use of financial regulation comes from recognizing the deep uncertainty that surrounds our current ability of monitoring and quantifying these risks. In a context where losses induced by physical events and transition frictions are hard to quantify and uncertainty about their unfolding in complex economic systems is pervasive, a precautionary approach centred around simple regulation aimed at avoiding worst-case scenarios (e.g. temperatures above 2 or 3 degrees) might be not just the only viable option from a practical perspective, but one that out-perform alternative solutions (Aikman et al., 2021; Chenet et al., 2021). Indeed, markets tend to perform poorly in delivering rapid, desirable, and efficient allocations of funding sources in presence of asymmetric information and uncertainty about future states of the world. Similarly, policy makers face difficulties in designing monetary-based instruments (e.g. carbon taxation) that are politically acceptable and effective when externalities are hard to quantify and markets may not work as perfectly as theory would prescribe.

Second, we need a good understanding of the risks of institutional change, so to put in place forward-looking risk mitigation strategies. Two main risks appear to be present in this case (Baer et al., 2021). First, transferring additional policy functions to an unelected technocratic institution without a proper mandate would mean moving this function away from democratic control. Second, an excessive diversification of policy functions would make central banks more prone to failure, especially if there are possible conflicts between them, and potentially less credible in their commitments. This could in turn have negative impacts on their capacity to maintain price and inflation stability. If brought to the extreme, this scenario could lead to a transfer of policy functions back to the governments and the loss of central banks independence.

Third, we need to identify a strategy to reach the institutional framework we believe is the most appropriate to deal with societal challenges. We identify two main possible avenues to achieve this, on which we expand in the next section.

 

Ideas for the future

A first avenue to ensure more effective climate action is to accept the limitations of risk assessment methods and start acting with whatever indication we can extract using existing datasets and methodologies. In situations where risks are easily computable, there is no cost to complexity: more information is always perceived to be better than less; and decisions should optimally weight all relevant factors. Contrarily, taking uncertainty seriously may imply that financial regulation built on simple indicators, available data and shared estimates outperform more complex assessments. This matches what Stern et al. define a “guardrail approach” (Stern et al., 2021): if there are actions that are likely to limit the chances of disastrous events and have moderate costs, they should be undertaken. For example, if capital requirements are used to limit banks’ risk-taking, one should ideally define them in a way to perfectly mirror the probability of default of each asset in their portfolio, possibly taking into account cross-exposures and interconnectedness. However, this entails an extremely complex use of data and modelling. Aikman et al. (2021) have shown that capital requirement rules based on Basel II criteria employing fixed rating agency outlooks outperformed approaches allowing internal estimation of counterparty-specific probability of defaults, especially in environments with changing regimes. The key question is whether and how a “fast and frugal’’ approach can be designed to address climate physical and transition risks.

Several initiatives that have been already undertaken in some countries aim at enriching the current regulatory framework, encompassing stress testing procedures, mandatory disclosure of climate-related risks, differentiated capital requirements for low- and high-carbon assets, and more. We argue that the success of these initiatives is largely dependent on their implementation strategy, which need to be (i) forward-looking; and (ii) immediately feasible. Forward-lookingness, in this context, indicates anticipation of conditions that have been hardly or not experienced. One simple way of doing this is through narratives and statistical analysis with higher weights on rare past events. This would reflect the intuition that a way to be prepared for unknown conditions is via fictitious scenario construction informed by the analysis of historically infrequent events. On a different ground, immediate feasibility refers to the fact that available or easy to retrieve information should be used to define regulations that are rapid to adopt, simple to monitor and flexibly adjustable as experience becomes available.

An example can be offered with respect to capital requirement regulation. While exact exposure of assets to weather events and climate policy is difficult to measure (as mentioned above), we have some systematised sources of information about susceptibility to both. In the same way rating agencies scores provide an imprecise yet easily accessible advice on credit risk, long term weather forecasts offer well-organised and public information about the likelihood of experiencing weather conditions significantly different than in the past, under scenarios of possible futures. Further, input-output data tracking flows of value added across sectors of economic activities are available to determine industries’ average emission intensity as well as reliance on high-emission intermediate products. It would be relatively easy to indicate whether locations are likely to experience more extreme weather with respect to the past and industries are likely to shrink production if carbon prices rise as much as in some rare historical event. At this point, Monte Carlo analysis can be used to analyse the minimum capital cushions that would be needed to absorb an extreme case where all assets within sectors and locations are “at risk” of default. Such an exercise could help the construction of a long run, dynamically-evolving and forward-looking target for the bank, and the key advantage of such an approach is that it just relies on information on sector and location, in addition to publicly available data about weather projections and value chain structure.

A second avenue for stronger climate action is to adopt bolder strategies of institutional change, in place of, or in addition to, adopting a different rule-making routing. Several alternatives exist. For instance, the mandate of delegated authorities can be modified so to include climate-related objectives. This was the path chosen by the United Kingdom, whose government in 2021 has updated the remit of both the Monetary Policy Committee and the Financial Policy Committee of the Bank of England to reflect the government’s strategy to achieve and economic system which is “environmentally sustainable and consistent with the transition to a net zero economy” (Sunak, 2021). Alternatively, new delegations can be imagined, so to transfer policy functions linked to the achievement of a clear forward-looking schedule of carbon prices to an independent institution capable of abstracting from electoral cycles, i.e. a ‘carbon central bank’ or a ‘carbon council’ (G30, 2020). This could reduce uncertainty around climate-related risks, acting not on the basis of quantified climate-related risks, but rather on the necessity of reaching politically-determined net-zero targets.

 

Conclusions

In this article we have discussed the evolving academic and policy debate on sustainable finance policy-making. While much can be done within current institutional arrangements — e.g. put a price on carbon or expand the information set available to markets via improved risk assessment methods and disclosure — this is unlikely to trigger a rapid and orderly decarbonisation process, due to multiple market failures and political obstacles.

In the face of the complex climate change challenge, simpler and more direct guidance should be offered to financial markets. While the dominant paradigm for studying decision-making in finance is based on rational management of known and (presumably) calculable risks, the presence of uncertainty can overturn the picture. Decision rules that attempt to achieve ever greater precision can become increasingly imprecise moving from theory to practice. Rules that attempt to weight optimally all the relevant information can sometimes generate poorer results than simple, `fast and frugal’ rules of thumb.

Unconventional thinking and policy-making, going beyond current practices and institutional boundaries, might thus be recommended. However, institutional changes may not be trivial, and could come at a cost. Reforming the mandate of the European Central Bank, for instance, is a particularly difficult task. The recent experiences of the Global Financial Crisis and the Covid-19 pandemics have also shown that some of the interventions carried out to face large downturns can encounter legal issues. It is thus crucial to explore all the possible ramifications of changing institutional practices and identify sustainable ways to ensure institutional coordination towards the decarbonisation objective.

 

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Notes

We are grateful to Jérôme Deyris, Esther Shears, Christopher Schroeder and Roberta Terranova for insightful comments on the article. The research leading to these results has received funding from the European Research Council (ERC) under the European Union’s Horizon 2020 Research and Innovation Programme (Grant agreement No 853050 – SMOOTH).

Footnotes[+]

Footnotes
↑1 University of Bologna.
↑2 Scuola Superiore Sant’Anna (Pisa) and RFF-CMCC European Institute on Economics and the Environment (EIEE, Milano).

Filed Under: 2021.2

Disclosure of Bank Fossil Fuel Exposures

April 20, 2022 by Winta Beyene, Manthos Delis and Steven Ongena

Authors

Winta Beyene[1]University of Zurich, Swiss Finance Institute., Manthos Delis[2]Montpellier Business School. and Steven Ongena[3]University of Zurich, Swiss Finance Institute, KU Leuven, NTNU, CEPR.[4]Corresponding author: steven.ongena@bf.uzh.ch. This paper is based on ongoing work by the authors done for the ECON Committee of the European Parliament. Beyene acknowledges financial support from … Continue reading

 

1. Introduction

Climate change is set to dramatically impact both financial markets and the wider economy. Most immediate risks that stem from climate change, relate to the risk of physical changes such as extreme weather events or alteration of climate patterns and the implied risk of economic impact and damages from such events. However, the impact of the transition to a low carbon economy manifests itself also in an alteration of the financial viability of a part of the capital stock and business models, particularly impacted are fossil-fuel companies and other high-carbon projects.

To meet the Paris Agreement goal to limit global warming to 2C or less, a major fraction of existing world fossil fuel reserves must go unburned (McGlade and Ekins, 2015). They calculate that globally, a third of oil reserves, half of gas reserves and over 80% of current coal reserves should remain unused from 2010 to 2050 in order to meet the target of 2C. This would make obsolete billions of dollars of existing and planned investments in oil, gas and coal as these resources are stranded (Carbon Tracker Initiative, 2017). “Stranded assets” are assets at risk of becoming obsolete from unanticipated or premature write-offs, downward revaluation or being converted to liabilities due to regulatory or environmental changes. Ongoing policy initiatives to move to cleaner technology in the near future and increasing climate change awareness accelerate the process in which firms with fossil fuel reserves will lose economic value.

In this context, fossil fuel stranded assets – e.g., coal mines, oilfields, and gas reserves – are a cause of financial stability concern. As the world moves towards a target of net zero carbon emissions, energy companies may see that large parts of their oil, gas and coal reserves will never be extracted and hence loose value. The more ambitious the timeline to move towards net zero carbon emissions, the less fossil fuels will be extracted.

Many financial institutions have warned that an abrupt and coordinated increase in carbon prices could cause a major shock to fossil fuel valuation, with the potential for systemic risk. A carbon bubble is a hypothesized bubble in the valuation of firms that heavily depend on fossil fuels as inputs in their production processes, such as those active in the oil, gas, and coal industry (Delis, de Greiff, Iosifidi, and Ongena, 2021; Atanasova and Schwartz, 2019). Yet Beyene, De Greiff, Delis, and Ongena (2021) show that banks continue to provide financing to fossil fuel firms that the bond market would not finance as long as they do not price the risk of stranded assets. Hence stranded assets risks may have shifted to large banks.

Paramount in this whole setting is the possible lack of information on both firm and bank exposures to the risk that fossil fuel reserves may become stranded. Hence therefor in this paper we review the information sources and disclosure regime of firm and bank fossil fuel exposures.

 

2. Information Sources on banks’ fossil fuel exposure

2.1. Disclosure of Fossil Fuel Exposure and Main Challenges

It is widely acknowledged that the disclosure of climate risks is an important driver in curbing global greenhouse gas emissions and achieving the goals of the 2015 Paris Agreement. High-quality information on firms’ climate risk exposures is critical for informed investment decisions as well as the appropriate pricing and management of these risks (Daniel, Litterman, and Wagner, 2016; Krueger, Sautner, and Starks, 2020). There is considerable evidence that investors value and demand climate risk disclosures and that the environmental, social, and governance performance of firms is strongly influenced by disclosure (Ilhan, Krueger, Sautner, and Starks, 2021). Moreover, with climate change increasingly considered to be a danger to the financial system, regulators across the globe have become concerned with the need for sound and consistent climate-related disclosure to protect financial stability (Financial Stability Board, 2021).

This growing demand for reliable information on transition risks led in recent years to the establishment of several climate change-related disclosure initiatives such as the Task Force on Climate-related Financial Disclosures (TCFD) or the CDP Financial Services Questionnaire. These voluntary initiatives generally aim to provide consistent climate-related financial risk disclosures to stakeholders. Regulatory efforts encourage climate-risk disclosures as well, some of them directly addressing financial institutions. For example, the UK is to enforce mandatory TCFD reporting from April 2022 on for large companies. Other jurisdictions that have already undertaken steps as well towards government-mandated disclosure for financial institutions are France, New Zealand, and Switzerland (Financial Stability Board, 2021; Mésonnier and Nguyen, 2021). Further, central banks and monetary authorities have been intensifying quantitative work aimed at capturing climate-related risks to financial stability (Basel Committee on Banking Supervision, 2021).

Challenges related to lack of data and assessment methods complicate accurate monitoring and mapping of the financial system exposures stranded assets risks. From a general public, as well as regulatory, perspective, quantifying financial institutions’ fossil fuel exposure is limited by a lack of publicly usable data. Stranded asset risks are almost invisible in corporate reports of financial institutions. The current sustainability reporting commonly focuses on greenhouse gas emissions and largely does not dictate any metrics that need to be reported with respect to the exposure to fossil fuel reserves and the fossil fuel sector. In principle, financial institutions themselves generate little or no greenhouse gas emissions in their day-to-day business, however, end-user scope 3 emissions from financing provided to fossil fuel firms provide needed insights into the impact of the financed fossil fuel procurements. Particularly, a focus on scope 3 emissions reporting by financial institutions with regard to the fossil fuel sector is material in the context of assessing risk given that much of the global stock of carbon emissions can be traced to a small number of upstream fossil fuel firms (Ilhan, Sautner, and Vilkov, 2021).

To assess the underlying fossil fuel exposure on a transaction level for banks that lend to, insurers that underwrite, and asset managers that invest in fossil fuel businesses, relevant information includes the greenhouse gas emissions profile, type, location, expected lifetime, and cost of production of the underlying fossil fuel asset (Fulton and Weber, 2015). This data required to link financing to stranded assets risks are often not readily available and financial institutions may need to collect data from fossil fuel firms public information or client questionnaires in order to be able to assess these risks.

Mapping fossil fuel exposure to stranded assets risk is a complex task. A proxy metric for the risk of stranded assets based on underlying fossil fuel reserves needs to consider current and future public policies, potential technology changes, and customer sentiment. Most importantly, financial institutions’ level of risk will depend on the regulatory and policy settings in a range of different jurisdictions. These assessment difficulties may exacerbate stranded assets risk and require particular guidance on how risk disclosure should be approached in this context. In any case, to achieve an assessment of stranded assets risk, the importance of effective disclosure from and monitoring of fossil fuel firms is immediate. Actual or expected changes in policy, technology, or the threat of litigation could prompt a rapid reassessment of the value of a large range of assets as changing costs and opportunities become apparent (Zenghelis and Stern, 2016). Overall, there is still not sufficient disclosure on unburnable carbon by the fossil fuel sector (Griffin and Myers Jaffe, 2018). For this reason, it appears that banks compared to other financiers are better suited to effectively assess stranded assets risks associated with debt or an investment portfolio. Nevertheless, Beyene et al. (2021) present evidence that banks in the syndicated loan market price the risk that assets held by fossil fuel firms strand less than the bond market.

Metrics for stranded assets, carbon footprint, or carbon intensity allow to better understand potential risks on a portfolio or firm level. Dedicated climate stress tests may be applied to evaluate the impacts of plausible environmental scenarios on, portfolios, institutions, and even financial markets as a whole. Such stress tests would also contribute to the safety and soundness of the financial system as the outcome may ultimately inform supervisory actions. For example, the European Central Bank is running an economy-wide climate stress test, which has been developed to assess the resilience of non-financial corporates (NFCs) and euro area banks to climate risks, under various assumptions in terms of future climate policies (Alogoskoufis, Dunz, Emambakhsh, Hennig, Kaijser, Kouratzoglou, Muñoz, Parisi, and Salleo, 2021). However, climate-stress testing methods that look at the exposure of investors require data that are often absent or of too low a resolution, and hard to access for researchers outside financial regulatory bodies.

In the following subchapters, we provide an overview of what sources of information are available to gauge the exposure of banks and, if possible, that of other financial institutions towards fossil fuel companies, and to what extent can that information be extracted from sources of mandatory disclosure.

 

2.2. Climate-Related Financial Disclosures

2.2.1. Voluntary Climate Action Initiatives and Fossil Fuel Exposure Disclosure Commitments

The most prominent example of a climate change-related disclosure initiative is the Task Force for Climate-related Financial Disclosure (TCFD), a global initiative that has been first implemented by the G20’s Financial Stability Board in 2015. A key element of the Task Force’s mission was the development of climate-related disclosures that “would enable stakeholders to understand better the concentrations of carbon-related assets in the financial sector and the financial system’s exposures to climate-related risks” (Financial Stability Board (2015)).

In 2017, the TCFD released for the first time its framework with a set of comprehensive recommendations and guidance on climate-related financial disclosures applicable to organizations across sectors and jurisdictions (Task Force on Climate-related Financial Disclosures, 2017; Task Force on Climate-related Financial Disclosures, 2020).

The Framework includes detailed recommendations on governance, strategy, risk management, and metrics and targets. In addition, the TCFD offered supplemental guidance for the financial as well as certain other sectors. With regards to disclosures on carbon-risk-related metrics; financial institutions are asked to report on more than just greenhouse gas emissions. Task Force recommends asset owners and asset managers to report a weighted average carbon intensity metric, although some asset managers effectively may be able to report weighted average carbon intensity for only a portion of the assets they manage given data availability and methodological issues. The same holds for insurance companies’ investment activities. Banks should provide the metrics used to assess the impact of (transition and physical) climate-related risks on their lending and other financial intermediary business activities in the short, medium, and long term and should also provide the amount and percentage of carbon-related assets relative to total assets as well as the amount of lending and other financing connected with climate-related opportunities (Task Force on Climate-related Financial Disclosures, 2017).

Today, the TCFD framework has somewhat become a global standard, having gained traction among public companies – over 2,300 non-financial and financial organizations officially support the TCFD. Moreover, governments have started to build on the TCFD to implement mandatory disclosure requirements. Recently, New Zealand, the United Kingdom, and Switzerland announced that TCFD reporting would become mandatory in their jurisdictions.

Bingler, Kraus, and Leippold (2021) explore whether voluntary reporting within the framework of the TCFD had a significant impact on disclosures of TCFD-supporting companies, or if it needs to be made mandatory. They come to the conclusion that firm’s announcing TCFD support does not lead to an increase in disclosures as firms cherry-pick to report primarily non-material climate risk information, disclosures on strategy and metrics and targets are generally lower. It has become increasingly clear that the voluntary sustainable-finance mandates backed by financial intermediaries need to be significantly more stringent than they are today.

CDP (formerly the Carbon Disclosure Project) is a UK-based organization that polls investor-requested companies worldwide each year about their carbon footprint, climate risks, and climate protection strategies. Over 300 financial institutions have been already reporting to CDP as of 2021. Key takeaways from the 2020 CDP questionnaires for the finance industry are that only about 25% of disclosing financial institutions report their financed emissions – 84 financial institutions worth US$27. Furthermore, only about half of the responding banks and asset managers and only less than 30% of insurers are taking action to align lending portfolios with a net-zero carbon world. Overall, the disclosure made to CDP also hints that institutional investors may be underestimating their climate-related risks. (CDP, 2021))

Along with voluntary reporting initiatives, common standards have been emerging that quantify the emissions financed by financial institutions and the impact of climate change on the industry’s portfolios and may enable a standardized way to assess climate-related risks in line with the TCFD and other disclosure regimes. The PCAF Global Greenhouse Gas Accounting and Reporting Standard for the Financial industry provides detailed methodological guidance to measure and disclose emissions for specific asset classes.[5]https://carbonaccountingfinancials.com/standard The Science Based Targets initiative (SBTi) released its Financial Sector Science-Based Targets Guidance that aims to enable companies to set emission reduction targets in line with leading climate science. To date, more than 70 financial institutions have publicly committed to set emissions reduction targets through the SBTi (Science-Based Targets initiative (SBTi), 2021).

In recent years, new efforts have emerged within the financial sector to coordinate climate actions for financial institutions and commit to align their lending and investment portfolios with net-zero emissions by 2050. These high-profile initiatives have made it harder for financial institutions to escape inaction. Among other things members of Net-Zero Alliances commit to establish an emissions baseline and annually measure and report the emissions profile of their portfolios and investment. Signatories also commit to transparent and rigorous accountability. As of December 2021, the Net-Zero Banking Alliance counts 95 members from 39 countries[6]https://www.unepfi.org/net-zero-banking/, representing 43% of global banking assets equivalent to US$ 66trn. The Net-Zero Insurer Alliance is joined by 15 global insurers[7]https://www.unepfi.org/net-zero-insurance/. The Net-Zero Asset Owner Alliance currently consists of 69 institutional investors representing over $10.4 trillion in assets under management. The Net Zero Asset Managers Initiative counts 220 signatories and represents $57 trillion in assets under management[8]https://www.netzeroassetmanagers.org. Signatories generally are supposed to support TCFD reporting and submit reports through the PRI and/or CDP platforms. The Glasgow Financial Alliance for Net Zero (GFANZ), chaired by Mark Carney, UN Special Envoy on Climate Action and Finance, unites financial institutions from the leading net-zero initiatives across the financial system. As of November 2021, GFANZ is joined by over 450 firms that are together responsible for assets in excess of US$130 trillion[9]https://www.gfanzero.com/progress-report/. In the context of these wide range commitments to net-zero across governments and financial institutions, Bolton, Kacperczyk, and Samama (2021) suggest that regulators could require that systemically important institutions estimate and report their carbon pathways to determine systemic execution risk associated with the necessary alignment of carbon emissions with global net-zero targets.

 

2.2.2. Mandatory Fossil Fuel Exposure Disclosure Commitments

Regulators are increasingly considering implementing mandatory carbon risk-related disclosures for financial institutions. Article 173-VI of French TECV law, for Transition Energétique et Croissance Verte (Energy Transition and Green Growth) that passed in 2015 and entered into force in January 2016 pioneered such government initiative[10]https://www.legifrance.gouv.fr/eli/loi/2015/8/17/DEVX1413992L/jo#JORFARTI000031045547, 17 August 2015. Article 173-VI of the law imposes – although on a comply-or-explain basis – climate-change and more general ESG reporting requirements on institutional investors registered in France and concerns all asset classes. In particular, it requires investors to report in their annual reports information on how they integrate ESG into their investment processes, on the integration of climate change-related risks – hence including stranded asset risks, on the alignment of voluntary decarbonisation targets with national and international goals. Investors are generally free to choose their preferred evaluation methodologies[11]https://www.unepfi.org/fileadmin/documents/PRI-FrenchEnergyTransitionLaw.pdf.

Mésonnier and Nguyen (2021) assess the effect of the introduction of Article 173-VI focusing on euro area investors’ holdings of bonds and stock issued by firms in the fossil energy industry. They show that imposing climate-related disclosures on financial institutions actually leads them to divest themselves of these carbon-intensive securities. However, the comply-or-explain principle, provides investors with broad flexibility, resulting in many of the financial services companies to not meet expectations with regards to reporting changes[12]https://www.i4ce.org/download/article-173-overview-of-climate-related-financial-dislosure-after-two-years-of-implementation/.

The UK government is the first of soon to be several governments to implement mandatory TCFD reporting. Financial Conduct Authority (FCA)-regulated asset managers and asset owners – including life insurers and pension providers – will have to disclose how they take climate-related risks and opportunities into account in managing investments. The implementation of the rule will be staggered, hence from 1 January 2022 the rule will come to effect for the largest firms with more than £50 billion in assets under management (or £25 billion assets under administration for asset owners) will, while it will be becoming into effect for smaller firms one year later[13]https://www.fca.org.uk/publication/policy/ps21-24.pdf.

New Zealand’s Financial Sector (Climate-related Disclosures and Other Matters) Amendment Act 2021 (FSAA) will prospectively require large financial organisations to disclose climate risks in line with TCFD recommendations. The new law will require around 200 large financial institutions covered by the FMC Act, including large registered banks, managers of registered investment schemes, licensed insurers, as well as most listed issuers, licensed insurers, and managers of investment schemes to start making climate-related disclosures for financial years commencing in 2023, with disclosures being made in 2024 at the earliest. A comply-or-explain approach creates exceptions from compliance[14]https://www.mbie.govt.nz/about/news/climate-related-disclosures-bill-passes-third-reading/ … Continue reading.

Switzerland is also gearing to implement binding TCFD reporting for large Swiss firms, including banks and insurance companies. The binding implementation of the TCFD recommendations is expected to take place from 2024 for the 2023 financial year; the Finance Ministry is set to prepare a legal text on mandatory reporting by the end of summer 2022[15]https://www.admin.ch/gov/en/start/documentation/media-releases.msg-id-84741.html.

While New Zealand, the UK, and Switzerland have implemented or announced that they will implement mandatory TCFD reporting, the EU is expectedly also on track to align sustainability reporting with TCFD recommendation. In April 2021, the European Commission adopted a proposal for the new Corporate Sustainability Reporting Directive (CSRD), which would introduce more detailed sustainability reporting requirements that are to be developed in consideration of existing standards such as the TCFD[16]https://ec.europa.eu/info/business-economy-euro/company-reporting-and-auditing/company-reporting/corporate-sustainability-reporting_en.

Table 1 provides an overview of the financial institutions’ main fossil fuel disclosure commitments.

 

2.3. Information from Financial Databases

In addition to the voluntary and binding disclosure discussed in the previous sections, investments in debt securities and stocks issued by fossil energy companies can be tracked via financial databases gathered by commercial data providers.

Equally important syndicated bank loans issued by fossil fuel firms can be tracked via DealScan from Refinitiv Loan Connector (in this context see for example their usage by Benincasa, Kabas, and Ongena (2021)). Other than banks, various types of institutional investors partake in syndicated bank loans despite having different costs and hence return expectations of providing debt capital. In contrast to traditional single-lender loans, syndicated loans are jointly extended by a group of lenders and are structured, arranged, and administered by one or several lead arrangers, that negotiate the key terms of the loans. As Figure 1 shows, this exposure to fossil fuel firms has not been decreasing much, an assessment that is consistent with more comprehensive credit data (in various ways) collected in Rainforest Action Network (2021) for example. To collect individual bilateral bank to firm credit exposures one needs access to the European Central Bank’s AnaCredit and/or to national credit registers.

While bank exposures to fossil fuel firms are one element of exposure to stranding risk, another one is the policy stringency of the countries where the fossil fuel reserves are located, the fossil firms are headquartered, and/or the fossil fuels are sold. To this end, Delis et al. (2021) and Beyene et al. (2021) measure climate policy risk with the Climate Change Performance Index by Germanwatch (see Burck, Marten, Bals, Hagen, Frisch, Höhne, and Nascimento, 2018) which is available for the period 2007-2017 for 58 countries. They both also use an alternative index called the Climate Change Cooperation Index by Bernauer and Böhmelt (2013) which evaluates countries’ overall climate policy performance, as well as performance in terms of political behavior (output) and emissions (outcome). However, this index only covers the period 1996-2014 (for up to 172 countries). In their work they find these two indices to perform quite similarly.

 

3. Conclusion

We think banks and other financial institutions may actually need enhanced international agreements on the proper accounting practices for carbon so that these institutions can all measure their progress towards net-zero the same way. At this stage unfortunately no institution can be entirely sure how much carbon the non-financial companies are producing because the data simply is not readily and universally available.

In this context it is promising to note that reporting on climate change risk under consideration of carbon risk is gaining traction, with ever more implementations triggered by voluntary disclosure commitments and recent government mandated reporting requirements. In this context, the Task Force on Climate-related Financial Disclosures (TCFD) recommendations are the first in line to become the much-needed global standards. Important to note however that there is first (somewhat worrying) evidence that voluntary commitments and comply-or explain approaches may not suffice to avoid climate cheap talk.

Stranded assets risk is complex to evaluate as it cannot be observed. Stranded assets risks are difficult to quantify; sound and consistent disclosure requirements are therefore essential to counteract jurisdictional differences/uncertainty as well as for the oversight of cross-border risks by financial authorities to protect financial stability. The current disclosure initiatives do not dictate what needs to happen in the fossil-fuel sector and are inclined more towards target-setting, and corporate engagement; this reliance on corporate reporting may be contributing to the current inertia in the financial sector.

 

Figure 1. Commercial Bank Exposure to Fossil Fuel Firms in DealScan

Notes: Figure 1 shows the total share of facilities extended to the fossil fuel sector relative to the total count of facilities provided by loan syndicates with at least one commercial bank. Similarly, Figure 1 also shows the fossil fuel share of the total commitment size of Dealscan facilities provided by loan syndicates with at least one commercial bank.

 

Table 1. Overview of Financial Institutions’ Main Fossil Fuel Disclosure Commitments

Notes. i Smaller investors, defined as those with a total balance sheet (or belonging to a group with a total balance sheet) of less than €500m, only must provide a general overview of how they integrate ESG factors.

 

References

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Footnotes[+]

Footnotes
↑1 University of Zurich, Swiss Finance Institute.
↑2 Montpellier Business School.
↑3 University of Zurich, Swiss Finance Institute, KU Leuven, NTNU, CEPR.
↑4 Corresponding author: steven.ongena@bf.uzh.ch. This paper is based on ongoing work by the authors done for the ECON Committee of the European Parliament. Beyene acknowledges financial support from the Swiss National Science Foundation. Ongena acknowledges financial support from European Research Council ADG 2016 – GA 740272 lending. The opinions in this paper are those of the authors and do not necessarily reflect the views of these institutions.
↑5 https://carbonaccountingfinancials.com/standard
↑6 https://www.unepfi.org/net-zero-banking/
↑7 https://www.unepfi.org/net-zero-insurance/
↑8 https://www.netzeroassetmanagers.org
↑9 https://www.gfanzero.com/progress-report/
↑10 https://www.legifrance.gouv.fr/eli/loi/2015/8/17/DEVX1413992L/jo#JORFARTI000031045547, 17 August 2015
↑11 https://www.unepfi.org/fileadmin/documents/PRI-FrenchEnergyTransitionLaw.pdf
↑12 https://www.i4ce.org/download/article-173-overview-of-climate-related-financial-dislosure-after-two-years-of-implementation/
↑13 https://www.fca.org.uk/publication/policy/ps21-24.pdf
↑14 https://www.mbie.govt.nz/about/news/climate-related-disclosures-bill-passes-third-reading/ https://environment.govt.nz/what-government-is-doing/areas-of-work/climate-change/mandatory-climate-related-financial-disclosures/
↑15 https://www.admin.ch/gov/en/start/documentation/media-releases.msg-id-84741.html
↑16 https://ec.europa.eu/info/business-economy-euro/company-reporting-and-auditing/company-reporting/corporate-sustainability-reporting_en

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