ABA Letter to ISSB on Climate-related Disclosures

Mr. Emmanuel Faber
International Sustainability Standards Board (ISSB)

Dear Mr. Faber:

The American Bankers Association (ABA) appreciates the opportunity to comment on the International Sustainability Standards Board’s (ISSB) Exposure Drafts IFRS S1 General Requirements for Disclosure of Sustainability-related Information and IFRS S2 Climate-related Disclosures (collectively as “ED”). The ED proposes a broad framework of disclosure related to climate risks and opportunities, governance, strategies, and risk management. This framework is supplemented by an array of required industry-specific metrics, of which four are specifically relevant to banking institutions. The ED, as well as the recent formation of the ISSB in general, responds to calls by various organizations (including the International Organization of Securities Commissions) for disclosure standards on climate change. While the requirement to disclose climate-related information in the future may vary from jurisdiction to jurisdiction, ISSB standards (and this ED) will likely be influential in worldwide efforts to provide investors with relevant decision-useful information.

ABA members consist of lenders, investment bankers, asset managers, investment analysts and custodians and, consequently, bring perspectives from both the users of the information as well as the preparers. Therefore, we bring perspectives from a wide range of stakeholders.

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