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Recent Projects

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  • McTeer Toney Gives Testimony on Climate Risk Disclosure in House Committee Hearing

    Heather McTeer Toney, Climate Justice Liaison for the Environmental Defense Fund and Senior Advisor to Moms Clean Air Force, testified in a hearing on corporate climate risk held by the House Financial Services Committee. Included with her submitted testimony is our report with the Environmental Defense Fund on how the Securities and Exchange Commission can issue new, mandatory disclosure rules focused on climate risk.

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  • Mandating Disclosure of Climate-Related Financial Risk Cover

    Mandating Disclosure of Climate-Related Financial Risk

    Climate change presents grave risk across the U.S. economy, including to corporations, their investors, the markets in which they operate, and the American public at large. Unlike other financial risks, however, climate risk is not routinely disclosed to the public. This report, authored by Policy Integrity and the Environmental Defense Fund, urges the Securities and Exchange Commission to issue new, mandatory disclosure rules focused on climate risk.

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  • Corporate Climate Risk: Assessment, Disclosure, and Action Cover

    Corporate Climate Risk: Assessment, Disclosure, and Action

    Conference Brief

    On October 2, 2020, the Institute for Policy Integrity and the Volatility and Risk Institute at NYU Stern School of Business convened a conference bringing together investors, companies, researchers, and regulators to discuss climate-related financial risks and identify opportunities to better assess, report, and act on them. This brief summarizes some of the major points of discussion from the conference, which featured different perspectives on various policy, economic, and legal issues. 

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  • Comments on OCC’s Fair Access Financial Services Rule

    The Office of the Comptroller of the Currency (OCC) proposed a rule that would preclude banks from taking climate risks into account when making decisions regarding the provision of financial services. We submitted joint comments explaining how OCC fails to consider or justify serious costs imposed by the rule. Climate risks pose a significant threat to the economic and operational health of firms in the energy sector and to the stability of the financial system as a whole.

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  • Amicus Briefs on Navigable Waters Protection Rule

    In April, the Environmental Protection Agency (EPA) and Army Corps of Engineers published the Navigable Waters Protection Rule, which considerably restricts the waters and wetlands that are federally protected under the Clean Water Act. We filed briefs in the Northern District of California and District of South Carolina focusing on the agencies’ economic analysis, which the agencies use to obscure the rule’s anticipated harms. We later filed in the Tenth Circuit Court of Appeals, the Northern District of New York, the District of Massachusetts, and the District of Maryland.

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  • Comments on HHS’s Sunset Rule

    The Department of Health and Human Services (HHS) has proposed to retrospectively and prospectively establish an "expiration date" for each of its regulations. Under the proposed rule, regulations would be automatically rescinded unless HHS first completes a restrospective review of the regulation's effects on small entities pursuant to the Regulatory Flexibility Act. We submitted comments criticizing the proposal, which is neither lawful nor rational.

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  • Ninth Circuit Affirms Injunctions of Public Charge Rule

    The U.S. Court of Appeals for the Ninth Circuit ruled that the Department of Homeland Security’s “Public Charge” rule is both contrary to statute and arbitrary and capricious. Our amicus brief in the case played a key role in shaping the decision. The Ninth Circuit adopts our core arguments, emphasizing how Homeland Security fails to assess the rule's harms and draws conclusions that are contradicted by the record.

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  • Presidential Transition Guidance

    As the presidential transition begins, the Institute for Policy Integrity has outlined recommended policy priorities for the Biden administration on climate, energy, and environmental policy, and related social equity outcomes. It is crucial that the incoming administration undertake aggressive reforms that are grounded in science and economics. In recent months, we published a series of reports highlighting actionable, near- and medium-term policy recommendations in several key areas.

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  • Amicus Brief in Appeal of Conscience Protections Decision

    Last fall, three federal courts—in the Southern District of the New York, the Northern District of California, and the Eastern District of Washington—vacated the Department of Health and Human Services’ conscience rule, which sought to expand healthcare providers’ rights to deny care on religious or moral grounds. In amicus briefs supporting the vacatur, Policy Integrity criticized HHS for, among other things, failing to consider the new policy’s likely health costs for women and LGBT individuals.

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  • Comments to Department of Labor on Shareholder Proxy Voting Rule

    A rule proposed by the Department of Labor would limit the shareholder rights of Employee Retirement Income Security Act (ERISA) participants. The rule, in particular, would eliminate opportunities for ERISA fiduciaries to vote on Environmental, Social, and Governance (ESG) proposals that have long-term financial benefits for retirements plans. We worked with the Environmental Defense Fund to submit comments detailing the flaws of the Department’s rule.  

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