The U.S. Chamber of Commerce’s (the Chamber) Center for Capital Markets Competitiveness submits these comments in response to the Commodity Future Trading Commission’s (CFTC) Request for Information on Climate-Related Financial Risk (Request). The Request seeks to inform the CFTC’s “understanding and oversight of climate-related financial risk as pertinent to the derivatives markets and underlying commodities markets.”

The Chamber believes that practical, flexible, predictable, and durable market-based solutions and mechanisms are at the core of efforts to address climate risk and are reflected in the actions of the Chamber’s members. Promoting private sector innovation across industry sectors will be central to solving climate change.

Climate-related financial services policy should also be informed by the best science and observations available and a rigorous assessment of available alternatives, outcomes, and cost benefit tradeoffs to ensure that the optimal policies are implemented. We must consider the significant progress that the private sector has spurred by committing billions of dollars to research and development that have led to the creation and implementation of innovations that help manage climate risk and accelerate emissions reductions.