the full range of issues created by the ilc exception in current law in a permanent, comprehensive and equitable manner. your decisions on these matters, whether by action or inaction, also will influence the structure, soundness and resiliency of our financial system and economy. as i will discuss, the board believes the best way to prevent this exception from further undermining the general policies that congress has established and further promoting competitive and regulatory imbalances within the banking system is to close the loophole in current law going forward. this is precisely the approach that congress has taken on previous occasions when earlier loopholes began to be used in unintended and potentially damaging ways. h. r. 698 would narrow, but not close, this loophole. the ilc exception and its origins the bhc act, originally enacted in 1956, provides a federal framework for the supervision and regulation of companies that own or control a bank and their affiliates. this comprehensive framework is intended to help protect the safety and soundness of corporately controlled banks that have access to the federal safety net and to maintain the general separation of banking and commerce in the united states. it does so principally in two ways. first, the act provides for all bank holding companies, including financial holding companies formed under the gramm - leach - bliley act ( glb act ), to be supervised on a consolidated or group - wide basis by the federal reserve. and second, the act prevents bank holding companies from engaging in general commercial activities and allows bank holding companies that qualify as financial holding companies to engage only in those activities that congress or the board ( in consultation with the treasury department, in certain cases ) has determined to be financial in nature or incidental or complementary to a financial activity. 1 the ilc exception allows a company to acquire an insured bank chartered in one of a handful of states – principally utah and california – without becoming a bank holding company under the bhc act and without abiding by the supervisory and regulatory framework established under that act. ironically, the special exception for ilcs was enacted in 1987 as part of a broader legislative package designed to close an earlier loophole – the so - called nonbank bank loophole – that increasingly was being exploited by large commercial and financial firms to evade the nonbanking restrictions and consolidated supervisory requirements of the bhc act. in 1987, congress acted affirmatively to close this loophole by passing the competitive equality banking act ( ceba ).

- led task force on climate - related financial disclosures ( tcfd ) that work toward consistent climate - related financial disclosures to improve transparency, reduce uncertainty, and help market participants appropriately assess and price climate - related risks and opportunities. 17 current voluntary disclosure practices are an important first step, but they are prone to variable quality, incompleteness, and a lack of actionable data. 18 ultimately, moving toward standardized, reliable, and mandatory disclosures could provide better access to the data required to appropriately manage risks. see, for example, united nations environment programme – finance initiative ( unep - fi ), “ extending our horizons : assessing credit risk and opportunity in a changing climate ” ( geneva : unep - fi, april 2018 ), https : / / www. unepfi. org / news / themes / climate - change / extending - our - horizons / ; unep - fi, “ beyond the horizon : new tools and frameworks for transition risk assessments from unep fi ’ s tcfd banking programme, ” ( geneva : unep - fi, october 2020 ), https : / / www. unepfi. org / publications / bankingpublications / beyond - the - horizon /. see, for example, network for greening the financial system ( ngfs ), “ guide to climate scenario analysis for central banks and supervisors, ” june 2020, https : / / www. ngfs. net / sites / default / files / medias / documents / ngfs _ guide _ scenario _ analysis _ final. pdf. federal advisory council ( fac ) record of meeting, ( february 4, 2021 ), https : / / www. federalreserve. gov / aboutthefed / files / fac - 20210204. pdf. task force on climate - related financial disclosures, final report : recommendations of the task force on climate - related financial disclosures ” ( new york : tcfd, june 2017 ), https : / / assets. bbhub. io / company / sites / 60 / 2020 / 10 / final - 2017 - tcfd - report - 11052018. pdf. see, for example, pedro faria, tony rooke, and esben madsen, pitfalls of climate - related disclosures, climate disclosure project, https : / / b8f65cb373b1b7b15febc70d8ead6ced550b