It has been publicly reported that the European Central Bank is planning to impose financial penalties (albeit modest ones) on certain banks that have failed to adequately prepare for climate change. Specifically, the European Central Bank has identified “nine outlier banks” which did not “adequately manage [climate] risks,” and are therefore subject to the potential imposition of fines. Notably, these banks include a major French bank that is the third-largest in Europe–so the European […]

On July 10, 2025, the Board of Governors of the Federal Reserve System (“Board”) proposed changes to its supervisory rating systems for large financial institutions (“LFIs”) and supervised insurance organizations (the “Proposal”). The changes address the meaning of “well managed” and are intended to more accurately reflect the strength of large Board-supervised financial institutions and the banking system as a whole.

Five members of the Board voted to issue the Proposal, while one voted against its issuance […]