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For release on delivery
10:00 a.m. EDT
October 7, 2021

Building Climate Scenario Analysis on the Foundations of Economic Research

Remarks by
Lael Brainard
Member
Board of Governors of the Federal Reserve System
at the
2021 Federal Reserve Stress Testing Research Conference
Federal Reserve Bank of Boston
Boston, Massachusetts
(via webcast)

October 7, 2021

I want to thank all of you for joining our research conference and the organizing
committee for inviting me to share some thoughts on climate scenario analysis. 1
Economic analysis suggests that climate change could have profound
consequences for the level, trend growth, and variability of economic activity over time
and across regions and sectors. Some of these effects could occur gradually, while others
could occur relatively quickly in the presence of “tipping points.” Policy, technology,
and behavioral responses could similarly have material financial consequences. Against
this backdrop, the Federal Reserve is carefully considering the potential implications of
climate-related risks for financial institutions and the financial system, with scenario
analysis emerging as a potential key analytical tool for that purpose.
Climate change is projected to have profound effects on the economy and the
financial system, and it is already inflicting damage. The Sixth Assessment Report by the
Intergovernmental Panel on Climate Change (IPCC) notes that “if global warming
increases, some compound extreme events with low likelihood in [the] past and current
climate will become more frequent, and there will be a higher likelihood that events with
increased intensities, durations and/or spatial extents unprecedented in the observational
record will occur.” 2

I am grateful to Luca Guerrieri and Cindy Vojtech as well as Kevin Stiroh of the Federal Reserve Board
for their assistance in preparing this text. These views are my own and do not necessarily reflect those of
the Federal Reserve Board or the Federal Open Market Committee.
2
See Intergovernmental Panel on Climate Change (2021; in press), “Summary for Policymakers,” in
V. Masson-Delmotte, P. Zhai, A. Pirani, S.L. Connors, C. Péan, S. Berger, N. Caud, Y. Chen, L.
Goldfarb, M.I. Gomis, M. Huang, K. Leitzell, E. Lonnoy, J.B.R. Matthews, T.K. Maycock, T. Waterfield,
O. Yelekçi, R. Yu, and B. Zhou, eds., Climate Change 2021: The Physical Science Basis. Contribution of
Working Group I to the Sixth Assessment Report of the Intergovernmental Panel on Climate
Change (Cambridge, United Kingdom: Cambridge University Press), p. SPM-35, paragraph C.3.3,
https://www.ipcc.ch/report/ar6/wg1/#SPM. The report also notes that “global surface temperature will
continue to increase until at least the mid-century under all emissions scenarios considered” (p. SPM-17,
headline statement B.1).
1

-2We can already see the growing costs associated with the increasing frequency
and severity of climate-related events. The total cost of U.S. weather and climate
disasters over the last 5 full years exceeds $630 billion, which is a record. 3 During this
period, massive flooding in the Midwest has caused billions of dollars in damages to
farms, homes, and businesses.4 The California Department of Insurance has documented
growing problems with the availability of fire insurance for homeowners, and the state
legislature provided new protections for wildfire survivors.5 Last year was the sixth
consecutive year that the United States experienced ten or more billion-dollar weather
and climate disasters. 6 And this summer, Hurricane Ida alone is estimated to have caused
more than $30 billion in insurance losses.7
The pandemic is a stark reminder that extreme events can materialize with little
warning and trigger severe financial losses and market disruptions, and the IPCC Sixth
Assessment Report is a reminder of the high uncertainty and potential costs associated
with climate-related risks. It will be important to systematically assess the resilience of

Damage estimate uses events listed in years 2016 through 2020 in the National Oceanic and Atmospheric
Administration’s Billion-Dollar Weather and Climate Disasters database, available on the agency’s website
at https://www.ncdc.noaa.gov/billions/events.
4
See Donnelle Eller (2021), “Climate Change-Driven ‘Midwest Water Hose’ Caused Massive 2019
Flooding in Iowa, Elsewhere, UI Researchers Find,” Des Moines Register, March 2,
https://www.desmoinesregister.com/story/money/agriculture/2021/03/02/ui-study-climate-change-midwestwater-hose-dumping-rain-university-iowa/6884486002 .
5
See California Department of Insurance (2018), “Insurance Commissioner Dave Jones Releases Report
Addressing Fire Insurance Availability Issues,” press release, January 4,
http://www.insurance.ca.gov/0400-news/0100-press-releases/2018/release002-18.cfm; and
California Department of Insurance (2021), “Wildfire Survivors Now Covered by New Insurance
Protections,” press release, July 27, http://www.insurance.ca.gov/0400-news/0100-pressreleases/2021/release078-2021.cfm.
6
See the National Oceanic and Atmospheric Administration’s Billion-Dollar Weather and Climate
Disasters database, in note 3.
7
See Leslie Scism (2021), “Ida Storm Damage Expected to Cost Insurers at Least $31 Billion,” Wall Street
Journal, September 22.
3

-3large financial institutions and the broader financial system to climate-related risk
scenarios.
Climate Scenario Analysis
As we are learning from the pandemic, risks emanating from outside the economy
can have devastating financial consequences. As part of our prudential and financial
stability responsibilities, we are developing scenario analysis to model the possible
financial risks associated with climate change and assess the resilience of individual
financial institutions and the financial system to these risks. The future financial and
economic consequences of climate change will depend on the severity of the physical
effects and the nature and speed of the transition to a sustainable economy. So it is
important to model the transition risks arising from changes in policies, technology, and
consumer and investor behavior and the physical risks of damages caused by an increase
in the frequency and severity of climate-related events as well as chronic changes, such
as rising temperatures and sea levels.
From the IPCC’s work, we know that the physical risks related to climate change
will grow over time, while the transition risks will depend in part on how abruptly policy,
technology, and behavioral changes take place. Since financial markets are forward
looking, a change in expectations regarding climate-related risks could lead to a sharp
repricing of assets at any time. Acute hazards, such as damaging hurricanes, or climaterelated policy changes could quickly alter perceptions of future risk or reveal new
information about the value of assets. Sudden asset price changes can lead to financial

-4instability when they interact with other vulnerabilities, such as high leverage or
correlated exposures.8
Scenario analysis is a useful tool in assessing the links between climate-related
risks and economic outcomes because it requires assessing the implications for financial
stability and individual financial institutions in a systematic way. The interactions across
institutions and market segments must be traced out, and missing data must be identified,
acquired, and analyzed, leading to a clearer picture of the transmission of risks. Scenario
analysis should ultimately facilitate estimating the possible effects on individual financial
institutions as well as on financial markets more broadly. By systematically modeling the
effects of climate-related risks across the financial system, scenario analysis can help
inform risk management at the level of individual financial institutions and more broadly.
Given that this conference is about stress testing, it is worth revisiting some
lessons from the first generation of bank stress tests. 9 Bank stress tests were developed at
the height of the 2007–09 financial crisis to provide a more systematic way to assess the
effects of complex and interrelated exposures within the financial system. The first test,
known as the Supervisory Capital Assessment Program (SCAP), used simplified models
with limited data inputs. Despite substantial uncertainty about the economy’s path, the
SCAP was broadly viewed as successful. It provided a solid foundation for building out

See the box “The Implications of Climate Change for Financial Stability” in Board of Governors of the
Federal Reserve System (2020), Financial Stability Report (Washington: Board of Governors, November),
pp. 58–59, https://www.federalreserve.gov/publications/files/financial-stability-report-20201109.pdf.
9
Several of the conference papers apply lessons from stress testing to the analysis of climate-related risks.
See Paulo Issler, Richard Stanton, Carles Vergara-Alert, and Nancy Wallace (2021), “Mortgage Markets
with Climate-Change Risk: Evidence from Wildfires in California”; Hyeyoon Jung, Robert Engle, and
Richard Berner (2021), “Climate Stress Testing”; and Henk Jan Reinders, Dirk Schoenmaker, and Mathijs
van Dijk (2021), “A Finance Approach to Climate Stress Testing.” These three papers can be downloaded
from the conference website, hosted by the Federal Reserve Bank of Boston
(https://www.bostonfed.org/news-and-events/events/federal-reserve-stress-testing-researchconference/2021.aspx).
8

-5the stress-testing program over the subsequent decade. The stress test infrastructure and
granular models and data that are currently available bear little resemblance to that first
stress test. In parallel, banks have improved their risk-management operations, and large
banks now routinely use their own stress tests to assess and manage their risks.
So what are the lessons for scenario analysis? Starting down the path of climate
scenario analysis, even with a rudimentary first attempt, will help with risk identification
and suggest useful lessons to inform subsequent improvements in modeling, data, and
financial disclosures. Although we should be humble about what the first generation of
climate scenario analysis is likely to deliver, the challenges we face should not deter us
from building the foundations now.
Learning from Climate Scenario Analysis in Other Countries
There is a growing international consensus that climate scenario analysis is a vital
tool for assessing the effects of climate-related risks on financial institutions and the
financial system. Since 2017, a group of regulators from across the world has been
sharing best practices regarding climate-related risk management within the Network of
Central Banks and Supervisors for Greening the Financial System (NGFS). The Federal
Reserve joined this international collaboration late last year.
Several countries have already made substantial progress on climate scenario
analysis. The scenarios produced by the NGFS, with appropriate tailoring to local
conditions, have been incorporated in climate change analysis by the European Central
Bank (ECB) as well as by financial regulators in Canada, France, and the United
Kingdom. For instance, the ECB published results from its analysis of climate-related
risks in September 2021, and the Bank of England published scenarios in June 2021 with

-6results expected in the middle of 2022.10 The Federal Reserve is actively learning from
these early adopters.
Overcoming Challenges in Implementing Climate Scenario Analysis
There are challenges to quantifying the effects of climate-related risks on the
economy and the financial system. Climate scenario analysis faces the challenge of
having to consider plausible but novel combinations of risks that are associated with
substantial uncertainty. For traditional financial risk scenarios, modelers can draw on the
historical record to help gauge the plausible repercussions for different asset classes as
well as the economic consequences at the national level. Even in the case of the COVID19 pandemic, modelers could draw useful lessons from previous pandemics, such as the
1918 influenza.11 By contrast, there may not be analogous historical precedents to draw
on in the formulation of appropriate climate scenarios and the quantification of their
effects on different asset classes, regions, and sectors.
In addition, climate scenario analysis may need to consider interdependencies
across the financial system. Banks and other financial institutions often rely on insurance
and other hedging strategies to reduce potential losses. With climate risk raising
insurance premiums charged to property owners or reducing the availability of insurance
in certain geographies and on certain asset classes, it may be important to assess the

For the European Central Bank, see ECB (2021), “Firms and Banks to Benefit from Early Adoption of
Green Policies, ECB’s Economy-wide Climate Stress Test Shows,” press release, September 22,
https://www.ecb.europa.eu/press/pr/date/2021/html/ecb.pr210922~59ade4710b.en.html; and Luis de
Guindos (2021), “Shining a Light on Climate Risks: The ECB’s Economy-wide Climate Stress Test,” ECB
Blog, March 18,
https://www.ecb.europa.eu/press/blog/date/2021/html/ecb.blog210318~3bbc68ffc5.en.html. For the Bank
of England, see Bank of England (2021), Key Elements of the 2021 Biennial Exploratory Scenario:
Financial Risks from Climate Change (London: BOE, June), https://www.bankofengland.co.uk/stresstesting/2021/key-elements-2021-biennial-exploratory-scenario-financial-risks-climate-change.
11
See Sergio Correia, Stephan Luck, and Emil Verner (2020), “Pandemics Depress the Economy, Public
Health Interventions Do Not: Evidence from the 1918 Flu,” working paper, June.
10

-7resilience of insurance and other hedging strategies and the associated implications for
supervised institutions. Stress could be transmitted through a sudden repricing of
insurance contracts or by a withdrawal of coverage, as we are already seeing in the case
of wildfires and flooding in certain areas. While reinsurance contracts and agreements
among investors can transfer risk across the financial system, some level of risk is likely
to remain. Climate-related risks could build up in hidden ways that could result in
cascading losses.
Using Established Economic Foundations for Transition Risks
The costs and timing of the transition to a low-carbon economy will depend on
hard-to-predict policy, technology, and behavioral changes.12 While an orderly and
steady transition to a sustainable economy may have manageable economic
consequences, more costly changes would likely accompany an abrupt transition. A
disorderly scenario could generate sizable economic consequences that vary substantially
across geographies, sectors, and assets. Some of these effects could manifest in the near
term if investment sentiment were to change suddenly. That said, the long tradition
within economics of estimating the effects of policy changes can be applied to the
modeling of transition risks, even disorderly scenarios. 13
Mapping the Economic Consequences of Physical Risks
Whereas existing economic tools can be applied to transition risks, the building
blocks for assessing the economic consequences of physical risks in the presence of
See International Energy Agency (2021), Net Zero by 2050: A Roadmap for the Global Energy Sector
(Paris: IEA, May), https://www.iea.org/reports/net-zero-by-2050.
13
See Robert Vermeulen, Edo Schets, Melanie Lohuis, Barbara Kölbl, David-Jan Jansen, and Willem
Heeringa (2018), “An Energy Transition Risk Stress Test for the Financial System of the Netherlands,”
Occasional Studies, vol. 16-7 (Amsterdam: De Nederlandsche Bank, October), available at
https://www.dnb.nl/en/publications/research-publications/occasional-studies/nr-7-2018-an-energytransition-risk-stress-test-for-the-financial-system-of-the-netherlands.
12

-8substantial uncertainty are still in development. The literature on the economic
consequences of physical risk is growing, but there are still some challenges in linking
this literature to the formulation of scenarios. 14 For instance, extrapolating from the
historical experience of sporadic extreme weather events may turn out to be misleading.
Economic activity has tended to rebound quickly after sporadic extreme weather events
in recent experience, often supported by significant reconstruction. In contrast, climate
change is an ongoing, cumulative process that could significantly increase the prevalence
and severity of extreme events as well as contribute to chronic changes. These
cumulative and chronic changes could have economic effects that differ substantively
from the historic experience, for example, if they contribute to shifts in the location of
economic activity or the sectoral composition within a region.
The physical manifestations of climate change could increase the volatility of
economic activity and slow economic growth.15 The cumulative effects associated with
climate change could lead to irreversible “tipping points” that introduce new climate
shocks and change the relationships between climate-related shocks and economic
variables. Tipping points, such as melting ice sheets and loss of permafrost or forests,
have the potential to create large disruptions in weather systems, regional water supplies,
and the habitability of large land masses. The potential cumulative effects of climate-

For instance, see Melissa Dell, Benjamin F. Jones, and Benjamin A. Olken (2012), “Temperature Shocks
and Economic Growth: Evidence from the Last Half Century,” American Economic Journal:
Macroeconomics, vol. 4 (July), pp. 66–95; Solomon Hsiang, Robert Kopp, Amir Jina, James Rising,
Michael Delgado, Shashank Mohan, D.J. Rasmussen, Robert Muir-Wood, Paul Wilson, Michael
Oppenheimer, Kate Larsen, and Trevor Houser (2017), “Estimating Economic Damage from Climate
Change in the United States,” Science, vol. 356 (June), pp. 1362–69; and Maximilian Auffhammer (2018),
“Quantifying Economic Damages from Climate Change,” Journal of Economic Perspectives, vol. 32 (Fall),
pp. 33–52.
15
See Network of Central Banks and Supervisors for Greening the Financial System (2020), NGFS Climate
Scenarios for Central Banks and Supervisors (Paris: NGFS, June),
https://www.ngfs.net/sites/default/files/medias/documents/820184_ngfs_scenarios_final_version_v6.pdf.
14

-9related shocks as well as potential climate-related tipping points for the economy and
financial system could reduce the accuracy of forecasts based on historical experience.16
Regional and Sectoral Differentiation in Projections of Revenues and Losses
The consequences of climate change are likely to be highly differentiated by
region and economic sector, which can bring both risks and opportunities for financial
institutions. Regional and sectoral differentiation has important implications for scenario
analysis. 17 Climate-related risks can be expected to have direct effects not only on the
valuation of assets on the balance sheets of financial institutions, but also on revenues
and costs. While standard models for projecting the net revenues of financial institutions
are typically driven by national-level proxies of aggregate demand, such as growth and
unemployment levels, additional sectoral and regional granularity will be necessary for
climate scenario analysis. And while standard models for projecting losses on assets
account for regional and sectoral characteristics, climate scenario analysis will require
capturing the potential intensification of climate-related risks.
Closing Data Gaps
These efforts to systematically assess climate-related risks will require substantial
work to address current data gaps. Financial institutions are collecting data and
developing scenario analysis to understand the potential effect of climate-related risks.
Similarly, the Federal Reserve is gathering key data resources, such as acquiring external

See, for instance, Simon Dietz, James Rising, Thomas Stoerk, and Gernot Wagner (2021), “Economic
Impacts of Tipping Points in the Climate System,” PNAS, vol. 118 (August),
https://www.pnas.org/content/118/34/e2103081118.
17
See, for instance, ECB (2021), “Firms and Banks to Benefit from Early Adoption of Green Policies,
ECB’s Economy-wide Climate Stress Test Shows,” press release, September 22,
https://www.ecb.europa.eu/press/pr/date/2021/html/ecb.pr210922~59ade4710b.en.html.
16

- 10 data and making existing publicly available climate data more useful for modeling and
research capabilities.
Current voluntary climate-related disclosures are an important first step in closing
data gaps, but they are prone to inconsistent quality and incompleteness. Without
harmonization of the definitions and methods underlying these disclosures, it will be
challenging to make comparisons across firms and exposures. Consistent, comparable,
and, ultimately, mandatory disclosures are likely to be vital to enable market participants
to measure, monitor, and manage climate risks on a consistent basis across firms. 18 The
Securities and Exchange Commission has responsibility for this critical workstream in
the United States. 19
Making Progress
Going forward, it will be important to improve our understanding of climaterelated financial risks and vulnerabilities. The Federal Reserve’s Supervision Climate
Committee is engaging with domestic stakeholders and other supervisors from a
prudential perspective. Ultimately, I anticipate it will be helpful to provide supervisory
guidance for large banking institutions in their efforts to appropriately measure, monitor,
and manage material climate-related risks, following the lead of a number of other
countries.

See, for instance, Network of Central Banks and Supervisors for Greening the Financial System (2021),
Progress Report on Bridging Data Gaps (Paris: NGFS, May),
https://www.ngfs.net/sites/default/files/medias/documents/progress_report_on_bridging_data_gaps.pdf;
and the communiqué on the Third G-20 Finance Ministers and Central Bank Governors Meeting, held
July 9–10, 2021, https://www.g20.org/wp-content/uploads/2021/07/Communique-Third-G20-FMCBGmeeting-9-10-July-2021.pdf.
19
See Gary Gensler (2021), “Prepared Remarks before the Principles for Responsible Investment ‘Climate
and Global Financial Markets’ Webinar,” Washington, July 28, https://www.sec.gov/news/speech/genslerpri-2021-07-28.
18

- 11 In addition, the Federal Reserve’s Financial Stability Climate Committee is
assessing climate-related risks to financial stability from a macroprudential perspective—
that is, one that considers the potential for complex interactions across the financial
system. Both the prudential and macroprudential work programs will benefit from the
development of climate scenario analysis.
Conclusion
Together these efforts can help ensure that the financial system is resilient to
climate-related risks and well positioned for the transition to a sustainable economy. Our
conversations with climate experts, large banking institutions, other financial
intermediaries, stakeholders, and regulators underscore the complexity of the connections
between the climate and economic and financial systems. To better understand these
connections, several foreign regulators have already undertaken climate scenario
analysis, affording us the opportunity to learn from their experiences. It will be helpful to
move ahead with the first generation of climate scenario analysis to identify risks and
potential issues and to inform subsequent refinements to our models and data. We will
reach better outcomes if we tackle these challenges through open dialogue and continued
engagement of the kind exemplified by today’s conference.