Status: Draft -- Not PublishedWill be live at 02/03/2021 14:51
IIF SFWG Response to TCFD Consultation on Forward-Looking Metrics
The IIF Sustainable Finance Working Group has submitted a response to the Taskforce on Climate-related Financial Disclosures (TCFD), and its Secretariat, on its public consultation on Forward-looking Financial Sector Metrics. The IIF strongly supports the objectives of this consultation as they relate to better understanding the evolution of metrics used and disclosed by financial institutions, and to understand alternative forward-looking metrics that could be disclosed by financial institutions in line with the TCFD recommendations as complements to existing metrics. However, engagements with IIF members have indicated that industry stakeholders have concerns regarding certain aspects of forward-looking metrics, which make it challenging to make robust and evidence-based judgements, or rank preferences regarding such metrics, at the current time.
As any TCFD-recommended forward-looking metrics may over time be reflected in official-sector frameworks and policies, it is important to ensure that steps towards standardization are appropriately phased, reflect the current state of industry practice, and the level of maturity of methodologies. Considering the nascent stage of methodologies available to produce forward-looking metrics, we perceive that a period of research, development, and consensus-building is necessary to ensure that desired outcomes of standardization (e.g. greater consistency and enhanced information) are achieved, and that potential negative unintended consequences (e.g. potential selective choice of approaches and assumptions to influence quantitative outputs) are minimized.