OCC Raises Concerns with California's Climate Disclosure Laws — 2026-10-29

WASHINGTON—The Office of the Comptroller of the Currency (OCC) today submitted a letter to the California Air Resource Board (CARB) addressing the serious legal and policy concerns raised by two California climate disclosure laws. In light of these concerns, the letter urges CARB to clarify that national banks and federal savings associations (banks) are not required to comply with these laws. As the OCC’s letter explains, the disclosure laws would be inconsistent with OCC regulation and safety and soundness; impose undue burden, particularly on smaller banks; harm California customers and disrupt customer relationships; and raise constitutional concerns, including under the Supremacy Clause. The application of the laws to banks may well run afoul of the legal framework for preemption and visitation, which are critical components of the dual banking system that Congress created over 150 years ago.