Brainard Downplays Near-Term Climate-Risk Stress Tests
Gov. Brainard today told a Democratic think tank that climate risk poses significant systemic hazard, a point she emphasized when the central bank’s most recent financial-stability report (see Client Report SYSTEMIC89) for the first time addressed climate risk.

Inter-Agency Computer-Security Notice Regs Reach the Cloud
Following FDIC board approval earlier this week, the Fed and OCC today formally joined the FDIC to issue an inter-agency NPR requiring banking organizations to notify their primary regulator in the event of a computer-security incident.

Toomey 13(3) Provision Limited to CARES Facilities
Scanned images of the Toomey language blocking further Fed 13(3) facilities suggests that the language does not, as some reports have suggested, broadly rewrite the Fed’s emergency powers.

OCC Extends Preemption Mantle
Continuing its strong stand on federal preemption, the OCC today issued a letter detailing the standards it uses for preempting state and local law, focusing on consumer-protection and interest-rate law and extending the preemption mantle still more explicitly to cover subsidiaries and address visitorial powers.