I 
119TH CONGRESS 
1ST SESSION H. R. 2823 
To require the Board of Governors of the Federal Reserve System, in con-
sultation with the heads of other relevant Federal agencies, to develop 
and conduct financial risk analyses relating to climate change, and for 
other purposes. 
IN THE HOUSE OF REPRESENTATIVES 
APRIL 10, 2025 
Mr. CASTEN introduced the following bill; which was referred to the Com-
mittee on Financial Services, and in addition to the Committee on Energy 
and Commerce, for a period to be subsequently determined by the Speak-
er, in each case for consideration of such provisions as fall within the ju-
risdiction of the committee concerned 
A BILL 
To require the Board of Governors of the Federal Reserve 
System, in consultation with the heads of other relevant 
Federal agencies, to develop and conduct financial risk 
analyses relating to climate change, and for other pur-
poses. 
Be it enacted by the Senate and House of Representa-
tives of the United States of America in Congress assembled, 
SECTION 1. SHORT TITLE. 
This Act may be cited as the ‘‘Climate Change Finan-
cial Risk Act of 2025’’. 
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SEC. 2. SENSE OF CONGRESS. 
It is the sense of Congress that— 
(1) 2024 was the warmest year on record glob-
ally and the first calendar year that the average 
global temperature exceeded 1.5 degrees Celsius 
above pre-industrial levels; 
(2) if current trends continue, average global 
temperatures over the long term are likely to sur-
pass 1.5 degrees Celsius above pre-industrial levels 
between 2030 and 2050; 
(3) global temperature rise has already resulted 
in an increased number of heavy rainstorms, coastal 
flooding events, heat waves, hurricanes, wildfires, 
and other extreme events; 
(4) since 1980— 
(A) the number of extreme weather events 
per year that cost the people of the United 
States more than $1,000,000,000 per event, ac-
counting for inflation, has increased signifi-
cantly; and 
(B) the total cost of extreme weather 
events in the United States has exceeded 
$2,915,000,000,000; 
(5) as physical impacts from climate change are 
manifested across multiple sectors of the economy of 
the United States— 
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(6) advances in energy efficiency and renewable 
energy technologies, as well as climate policies and 
shifting societal preferences, will— 
(A) reduce global demand for fossil fuels; 
and 
(B) expose transition risks for fossil fuel 
companies and investors domestically and glob-
ally, and for companies and investors in other 
energy-intensive industries, which could include 
trillions of dollars of stranded assets around the 
world; 
(7) climate change poses uniquely far-reaching 
risks to the financial services industry, including 
with respect to credit, counterparty, and market 
risks, due to the number of sectors and locations im-
pacted and the potentially irreversible scale of dam-
age; 
(8) weaknesses in how a financial institution 
identifies, measures, monitors, and controls for the 
physical risks and transition risks associated with 
climate change could adversely affect the safety and 
soundness of a financial institution; 
(9) financial institutions must take a consistent 
approach to assessing climate-related financial risks 
and incorporating those risks into existing risk man-
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agement practices, which should be informed by sce-
nario analysis; 
(10) the Board of Governors conducts annual 
assessments of the capital adequacy and capital 
planning practices of the largest and most complex 
banking organizations (referred to in this section as 
‘‘stress tests’’) in order to promote a safe, sound, 
and efficient banking and financial system; 
(11) as of the date of enactment of this Act— 
(A) the stress tests conducted by the 
Board of Governors are not designed to reflect 
the physical risks or transition risks posed by 
climate change; and 
(B) the Board of Governors has conducted 
1 pilot climate scenario analysis exercise with 
only 6 United States banking organizations; 
(12) the Board of Governors— 
(A) has stated that economic effects of cli-
mate change and the transition to a lower car-
bon economy pose an emerging risk to the safe-
ty and soundness of financial institutions and 
the financial stability of the United States; 
(B) has the authority under section 39 of 
the Federal Deposit Insurance Act (12 U.S.C. 
1831p–1) and section 165 of the Financial Sta-
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bility Act of 2010 (12 U.S.C. 5365) to take 
into account the potentially systemic impact of 
climate-related risks on the financial system to 
preserve the safety and soundness of supervised 
institutions and the financial stability of the 
United States; and 
(C) should develop new analytical tools 
with longer time horizons to accurately assess 
and manage the risks described in subpara-
graph (B); 
(13) the Climate-Related Market Risk Sub-
committee of the Commodity Futures Trading Com-
mission has identified the importance of researching 
‘‘climate-related ‘sub-systemic’ shocks to financial 
markets and institutions in particular sectors and 
regions of the United States’’; and 
(14) the Financial Stability Oversight Council 
likewise identified ‘‘[c]limate change [a]s an emerg-
ing threat to the financial stability of the United 
States’’ and recommended that members of the 
Council, including the Board of Governors, take ac-
tion to ‘‘strengthen the financial system and make 
it more resilient to climate-related shocks and 
vulnerabilities’’. 
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SEC. 3. DEFINITIONS. 
In this Act: 
(1) BANK
HOLDING
COMPANY.—The term 
‘‘bank holding company’’ has the meaning given the 
term in section 102(a) of the Financial Stability Act 
of 2010 (12 U.S.C. 5311(a)). 
(2) BOARD OF GOVERNORS.—The term ‘‘Board 
of Governors’’ means the Board of Governors of the 
Federal Reserve System. 
(3) CLIMATE SCIENCE LEADS.—The term ‘‘cli-
mate science leads’’ means— 
(A) the Administrator of the National Oce-
anic and Atmospheric Administration; 
(B) the Administrator of the Environ-
mental Protection Agency; 
(C) the Secretary of Energy; 
(D) the Assistant Secretary for the Office 
of International Affairs of the Department of 
Energy; 
(E) the Administrator of the National Aer-
onautics and Space Administration; 
(F) the Assistant Secretary for the Bureau 
of Oceans and International Environmental and 
Scientific Affairs of the Department of State; 
(G) the Director of the United States Geo-
logical Survey; 
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(H) the Secretary of the Interior; 
(I) the Director of the National Climate 
Assessment; 
(J) the individual from the United States 
elected to the Intergovernmental Panel on Cli-
mate Change Bureau; 
(K) the Permanent Representative of the 
United States to the World Meteorological Or-
ganization; and 
(L) the head of any other Federal agency 
that the Board of Governors determines to be 
appropriate. 
(4) COVERED ENTITY.—The term ‘‘covered en-
tity’’ means— 
(A) a nonbank financial company or bank 
holding company that has not less than 
$250,000,000,000 in total consolidated assets; 
and 
(B) a nonbank financial company or bank 
holding company— 
(i) 
that 
has 
not 
less 
than 
$100,000,000,000 in total consolidated as-
sets; and 
(ii) with respect to which the Board of 
Governors determines the application of 
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subparagraph (C) of section 165(i)(1) of 
the Financial Stability Act of 2010 (12 
U.S.C. 5365(i)(1)), as added by section 6 
of this Act, is appropriate— 
(I) to— 
(aa) prevent or mitigate 
risks to the financial stability of 
the United States; or 
(bb) promote the safety and 
soundness of the company; and 
(II) after taking into consider-
ation— 
(aa) the capital structure, 
riskiness, complexity, financial 
activities, and size of the com-
pany, including the financial ac-
tivities of any subsidiary of the 
company; and 
(bb) any other risk-related 
factor that the Board of Gov-
ernors determines to be appro-
priate. 
(5) NONBANK FINANCIAL COMPANY.—The term 
‘‘nonbank financial company’’ has the meaning given 
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the term in section 102(a)(4)(C) of the Financial 
Stability Act of 2010 (12 U.S.C. 5311(a)(4)(C)). 
(6) PHYSICAL
RISKS.—The term ‘‘physical 
risks’’ means financial risks to assets, locations, op-
erations, or value chains that result from exposure 
to physical, climate-related effects, including from— 
(A) increased average global temperatures; 
(B) increased severity and frequency of ex-
treme weather events; 
(C) increased flooding; 
(D) sea level rise; 
(E) ocean acidification; 
(F) increased severity and frequency of 
heat waves; 
(G) increased frequency of wildfires; 
(H) decreased arability of farmland; and 
(I) decreased availability of fresh water. 
(7) SURVEYED ENTITY.—The term ‘‘surveyed 
entity’’ means a bank holding company, nonbank fi-
nancial company, or other entity that— 
(A) is supervised by the Board of Gov-
ernors, the Office of the Comptroller of the 
Currency, or the Federal Deposit Insurance 
Corporation; 
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(B) has total consolidated assets of not 
less than $10,000,000,000; and 
(C) is not a covered entity. 
(8) TECHNICAL
DEVELOPMENT
GROUP.—The 
term ‘‘Technical Development Group’’ means the 
Climate Risk Scenario Technical Development Group 
established under section 4(a). 
(9) TRANSITION RISKS.—The term ‘‘transition 
risks’’ means financial risks that are attributable to 
climate change mitigation and adaptation, including 
efforts to reduce greenhouse gas emissions and 
strengthen resilience to the impacts of climate 
change, including— 
(A) costs relating to— 
(i) international treaties and agree-
ments; 
(ii) Federal, State, and local policies; 
(iii) new technologies; 
(iv) changing markets; 
(v) reputational impacts relevant to 
changing consumer behavior; and 
(vi) litigation; and 
(B) a loss in the value, or the stranding, 
of assets due to any of the costs described in 
subparagraph (A). 
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(10) VALUE CHAIN.—The term ‘‘value chain’’— 
(A) means the total lifecycle of a product 
or service, both before and after production of 
the product or service, as applicable; and 
(B) may include the sourcing of materials, 
production, and disposal with respect to the 
product or service described in subparagraph 
(A). 
SEC. 4. CLIMATE RISK SCENARIO TECHNICAL DEVELOP-
MENT GROUP. 
(a) ESTABLISHMENT.—The Board of Governors shall 
establish a technical advisory group to be known as the 
‘‘Climate Risk Scenario Technical Development Group’’. 
(b) MEMBERSHIP.— 
(1) COMPOSITION.—The Technical Develop-
ment Group shall be composed of 10 members— 
(A) 5 of whom shall be climate scientists, 
with a demonstrated record of peer-reviewed 
publications and professional contributions to 
climate modeling, climate risk assessment, or 
related areas; and 
(B) 5 of whom shall be economists, with 
expertise in either the United States financial 
system or the financial risks posed by climate 
change. 
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(2) SELECTION.—The Board of Governors shall 
select the members of the Technical Development 
Group after consultation with the climate science 
leads. 
(c) DUTIES.—The Technical Development Group 
shall— 
(1) provide recommendations to the Board of 
Governors regarding the development of, and up-
dates to, the climate change risk scenarios under 
section 5; 
(2) after the establishment of the climate 
change risk scenarios under section 5, determine the 
financial and economic risks resulting from those 
scenarios; 
(3) make any final work product, and any infor-
mation used in the development of the final work 
product, publicly available; 
(4) provide technical assistance to covered enti-
ties in assessing physical risks or transition risks; 
and 
(5) provide publicly available resources to enti-
ties that are not covered entities to help those enti-
ties assess physical risks and transition risks. 
(d) PROHIBITION ON COMPENSATION.—Members of 
the Technical Development Group shall serve without pay. 
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(e) INAPPLICABILITY OF CHAPTER 10 OF TITLE 5, 
UNITED STATES CODE.—Chapter 10 of title 5, United 
States Code, shall not apply with respect to the Technical 
Development Group. 
SEC. 5. DEVELOPMENT AND UPDATING OF CLIMATE 
CHANGE RISK SCENARIOS. 
(a) IN GENERAL.— 
(1) INITIAL DEVELOPMENT.—Not later than 1 
year after the date of enactment of this Act, the 
Board of Governors, in coordination with the climate 
science leads, and taking into consideration the rec-
ommendations of the Technical Development Group, 
shall develop 3 separate climate change risk sce-
narios as follows: 
(A) One scenario that assumes an average 
increase in global temperatures of 1.5 degrees 
Celsius above pre-industrial levels. 
(B) One scenario that assumes an average 
increase in global temperatures of 2 degrees 
Celsius above pre-industrial levels. 
(C) One scenario that— 
(i) assumes the likely and very likely 
average increase in global temperatures 
that can be expected, taking into consider-
ation the extent to which national policies 
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and actions relating to climate change have 
been implemented, as of the date on which 
the scenario is developed; and 
(ii) does not take into consideration 
commitments for national policies and ac-
tions relating to climate change that, as of 
the date described in clause (i), have not 
been implemented. 
(2) INTERNATIONAL COORDINATION.—In devel-
oping and updating the 3 scenarios required under 
this subsection, the Board of Governors shall take 
into consideration analytical tools and best practices 
developed by international banking supervisors relat-
ing to climate risks and scenario analysis in an ef-
fort to develop consistent and comparable data-driv-
en scenarios. 
(3) RECOMMENDATIONS.—If the Technical De-
velopment Group determines that the average in-
crease in global temperatures described in subpara-
graph (A) or (B) of paragraph (1) is no longer sci-
entifically valid, the Technical Development Group 
may recommend that the Board of Governors, in co-
ordination with the climate science leads, update the 
average increase in global temperatures described in 
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the applicable subparagraph to reflect the most cur-
rent assessment of climate change science. 
(b) CONSIDERATIONS.—In developing and updating 
each of the 3 scenarios required under subsection (a), the 
Board of Governors, in coordination with the climate 
science leads, shall account for physical risks and transi-
tion risks that may disrupt business operations across the 
global economy, including through— 
(1) disruptions with respect to— 
(A) the sourcing of materials; 
(B) production; 
(C) transportation; and 
(D) the disposal of products and services; 
(2) changes in the availability and prices of raw 
materials and other inputs; 
(3) changes in agricultural production and with 
respect to food security; 
(4) direct damages to fixed assets; 
(5) increases in costs associated with insured or 
uninsured losses; 
(6) changes in asset values; 
(7) impacts on— 
(A) aggregate demand for products and 
services; 
(B) labor productivity; 
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(C) asset liquidity; and 
(D) credit availability; 
(8) mass migration and increases in disease and 
mortality rates; 
(9) international conflict, as such conflict re-
lates to global economic activity and output; and 
(10) changes in any other microeconomic or 
macroeconomic condition that the Board of Gov-
ernors, in coordination with the climate science 
leads, determines to be relevant. 
SEC. 6. CLIMATE-RELATED ENHANCED SUPERVISION FOR 
CERTAIN NONBANK FINANCIAL COMPANIES 
AND BANK HOLDING COMPANIES. 
Section 165(i)(1) of the Financial Stability Act of 
2010 (12 U.S.C. 5365(i)(1)) is amended— 
(1) in subparagraph (B)(i), by inserting ‘‘except 
as provided in subparagraph (C)(ii)(I),’’ before 
‘‘shall provide’’; and 
(2) by adding at the end the following: 
‘‘(C) BIENNIAL TESTS REQUIRED.— 
‘‘(i) DEFINITIONS.—In this subpara-
graph— 
‘‘(I) the term ‘capital distribu-
tion’ has the meaning given the term 
in section 225.8(d)(4) of title 12, 
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Code of Federal Regulations, as in ef-
fect on the date of enactment of this 
subparagraph; 
‘‘(II) the term ‘capital policy’ has 
the meaning given the term in section 
225.8(d)(7) of title 12, Code of Fed-
eral Regulations, as in effect on the 
date of enactment of this subpara-
graph; and 
‘‘(III) the terms ‘climate science 
leads’ and ‘covered entity’ have the 
meanings given those terms in section 
3 of the Climate Change Financial 
Risk Act of 2025. 
‘‘(ii) TESTS.— 
‘‘(I) IN GENERAL.—The Board of 
Governors, in coordination with the 
appropriate primary financial regu-
latory 
agencies 
and 
the 
climate 
science leads, shall conduct biennial 
analyses in which each covered entity 
shall be subject to evaluation, under 
an adverse set of conditions, of wheth-
er that covered entity has the capital, 
on a total consolidated basis, nec-
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essary to absorb financial losses that 
would arise under each climate change 
risk scenario developed under section 
5 of the Climate Change Financial 
Risk Act of 2025. 
‘‘(II) INITIAL
TESTS.—With re-
spect to each of the first 3 analyses 
conducted under subclause (I)— 
‘‘(aa) the covered entity to 
which such an analysis applies 
shall not be subject to any ad-
verse consequences as a result of 
the analysis; and 
‘‘(bb) the Board of Gov-
ernors shall— 
‘‘(AA) not later than 60 
days after the date on which 
the 
Board 
of 
Governors 
completes the analysis, make 
a summary of the analysis 
publicly available; and 
‘‘(BB) submit a copy of 
the results of the analysis to 
the Committee on Banking, 
Housing, and Urban Affairs 
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of the Senate and the Com-
mittee on Financial Services 
of the House of Representa-
tives. 
‘‘(III) CLIMATE
RISK
RESOLU-
TION PLAN.— 
‘‘(aa) IN GENERAL.—Except 
with respect to the first analysis 
conducted under subclause (I), 
each covered entity shall, before 
being subject to an analysis 
under that subclause, submit to 
the Board of Governors a resolu-
tion plan with respect to climate 
risk planning (referred to in this 
subclause as a ‘climate risk reso-
lution plan’), which shall be 
based on the results of the most 
recently conducted analysis of the 
covered entity under that sub-
clause. 
‘‘(bb) CONTENTS.—Each cli-
mate risk resolution plan re-
quired under item (aa) shall in-
clude— 
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‘‘(AA) a capital policy 
with respect to climate risk 
planning; and 
‘‘(BB) qualitative and 
quantitative targets for bal-
ance sheet and off-balance 
sheet exposures, and other 
business 
operations, 
that 
remedy vulnerabilities identi-
fied in the most recently 
conducted analysis of the 
applicable 
covered 
entity 
under subclause (I). 
‘‘(cc) 
REJECTION.—The 
Board of Governors may object 
to a climate risk resolution plan 
submitted by a covered entity 
under item (aa) if the Board of 
Governors determines that— 
‘‘(AA) the covered enti-
ty has not demonstrated 
that such plan is reasonable 
to maintain capital above 
each minimum regulatory 
capital ratio on a pro forma 
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basis under the adverse set 
of conditions described in 
subclause (I); 
‘‘(BB) the climate risk 
resolution plan is otherwise 
not reasonable or appro-
priate, including because the 
climate risk resolution plan 
no longer provides fair serv-
ices to vulnerable and dis-
advantaged communities; 
‘‘(CC) the assumptions 
and analysis underlying the 
climate risk resolution plan, 
or the methodologies and 
practices that support that 
plan, are not reasonable or 
appropriate; or 
‘‘(DD) the climate risk 
resolution 
plan 
otherwise 
constitutes an unsafe or un-
sound practice. 
‘‘(dd) GENERAL
DISTRIBU-
TION LIMITATION.—If the Board 
of Governors objects to a climate 
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risk resolution plan submitted by 
a covered entity under item (aa), 
the covered entity may not make 
any capital distribution, other 
than a capital distribution arising 
from the issuance of a regulatory 
capital instrument eligible for in-
clusion in the numerator of a 
minimum 
regulatory 
capital 
ratio.’’. 
SEC. 7. SUB-SYSTEMIC EXPLORATORY SURVEY. 
(a) DEVELOPMENT OF SURVEY.—The Board of Gov-
ernors, in consultation with the Comptroller of the Cur-
rency and the Board of Directors of the Federal Deposit 
Insurance Corporation, shall develop a survey to assess— 
(1) the ability of surveyed entities to withstand 
each climate risk scenario developed under section 5; 
(2) which surveyed entities possess a large con-
centration of business activities in geographical 
areas or industries that are significantly exposed to 
the short- and long-term impacts of climate change; 
and 
(3) how the surveyed entities identified under 
paragraph (2) plan to make adaptations to the busi-
ness models and capital planning of those entities in 
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response to the risks presented in each climate 
change risk scenario developed under section 5. 
(b) ADMINISTRATION OF SURVEY.— 
(1) INITIAL ADMINISTRATION.— 
(A) IN GENERAL.—Not later than 1 year 
after the completion of the first analysis under 
subparagraph (C) of section 165(i)(1) of the Fi-
nancial Stability Act of 2010 (12 U.S.C. 
5365(i)(1)), as added by section 6 of this Act, 
the Board of Governors, in consultation with 
the Comptroller of the Currency and the Board 
of Directors of the Federal Deposit Insurance 
Corporation, shall administer the survey devel-
oped under subsection (a) to each surveyed en-
tity. 
(B) ASSESSMENT AND REPORT.—Not later 
than 18 months after the date on which the 
Board of Governors completes the administra-
tion of the survey under subparagraph (A), the 
Board of Governors shall publicly release a re-
port that— 
(i) summarizes the results of the sur-
vey; and 
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(ii) analyzes whether the planned ac-
tions of the surveyed entities, in the aggre-
gate, are plausible and would be effective. 
(2) SUBSEQUENT ADMINISTRATION.— 
(A) IN GENERAL.—Not later than 2 years 
after the date on which the Board of Governors 
releases the report required under paragraph 
(1)(B), and biennially thereafter, the Board of 
Governors shall readminister to each surveyed 
entity the survey developed under subsection 
(a). 
(B) SUBSEQUENT
REPORT.—Not later 
than 180 days after the date on which each sur-
vey described under subparagraph (A) is com-
pleted, the Board of Governors shall publicly re-
lease a report that summarizes the results of 
the survey, which shall include the analysis de-
scribed in paragraph (1)(B)(ii). 
(c) EFFECT OF SURVEY PARTICIPATION.—In any re-
port released with respect to a survey conducted under 
this section, the Board of Governors may not identify any 
individual surveyed entity that responded to the survey. 
(d) RULE OF CONSTRUCTION.—Nothing in this sec-
tion may be construed to preclude the Board of Governors 
from pursuing an enforcement action against a surveyed 
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entity because of a violation discovered by the Board of 
Governors during an examination of the surveyed entity 
that is independent of a survey administered under this 
section. 
Æ 
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