Read the entire response here: https://www.regulations.gov/comment/NCUA-2023-0045-0024
On behalf of the United Nations Federal Credit Union (UNFCU), we would like to thank the National Credit
Union Administration Board (NCUA) for soliciting comments and information on the growing challenge to
credit unions (CUs) posed by climate-related risks in its recent Request for Information and Comment
(RFI). We acknowledge the importance of addressing this topic given the critical and accelerating risks
caused by climate change as noted in the overview of the RFI.
CUs are contributing to climate change while simultaneously being affected by it. As such, managing this
risk has become an essential component of proper credit union management. As described more fully in
our responses, UNFCU’s suggestions to better support the management of climate risk can be
1) Integration of climate risk into Enterprise Risk Management (ERM) programs;
2) Use of transparent reporting using voluntary frameworks;
3) Increased education to promote climate risk awareness and resilience to support risk
4) Higher coverage limit for the National Flood Insurance Program (NFIP).