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climate-risk-disclosure-act-support-051121-45b453a6c238a69e.pdf
The document is a formal letter of support for the Climate Risk Disclosure Act of 2021, arguing that standardized climate risk reporting is essential for investor protection and financial stability. It highlights that current corporate disclosures are unstandardized and insufficient, while noting that the U.S. Commodity Futures Trading Commission has identified climate change as a major risk to the U.S. financial system.
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Document type: Statement
The Macroeconomic Impact of COVID-19 on Africa
The document examines the two-wave economic impact of COVID-19 in Africa, highlighting the first wave's disruption of trade, commodity prices, and remittances, and the second wave's risk of sovereign credit downgrades and debt defaults. It argues that limited fiscal space and high debt-to-GDP ratios leave many African nations unable to fund recovery, suggesting that central banks use monetised interventions and governments leverage digital technologies to maintain financial stability.
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Document type: Briefing
Understanding the Impact of a Low-Carbon Transition on Uganda's Planned Oil Industry
The analysis examines the declining value of Uganda's oil reserves in the Albertine Basin, the East African Crude Oil Pipeline, and the Hoima oil refinery. It finds that the value of these reserves has already decreased by over $40 billion since 2013, with further declines expected under a Paris Agreement-aligned low-carbon transition.
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Document type: Research paper
Impact of Covid-19 on the Malawian Insurance Sector
The COVID-19 pandemic disrupted the Malawian insurance sector by stagnating sales due to a reliance on physical distribution and reducing premium income as customers struggled to pay. Insurers responded by digitising the value chain, offering premium holidays, and adopting remote work infrastructure. While the pandemic increased demand for critical illness and income protection products, it created liquidity and solvency pressures due to decreased investment returns and higher operational expenses for digitisation. The Reserve Bank of Malawi provided regulatory relief by suspending on-site examinations and offering a one-year holiday on supervisory levies.
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Document type: Report
Impact of COVID-19 on the Ghanaian insurance sector
The report details how COVID-19 disrupted the Ghanaian insurance sector, citing operational challenges due to lockdowns, financial risks from declining premium income and volatile investment assets, and the regulatory response of the National Insurance Commission (NIC). It highlights a shift toward digitalization and the broader economic downturn in Ghana, including a GDP growth estimate reduction from 6.8% to 2.6% for 2020.
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Document type: Report
Impact of Covid-19 on Financial Stability in Africa
The document examines how Covid-19 triggered financial instability in Africa through capital outflows, falling commodity prices, and sovereign credit downgrades, while recommending the development of local capital markets and continental policy coordination to enhance resilience.
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Document type: Research paper
US Financial Regulators Should Address Climate Risks That Threaten to Destabilize Our Economy
Environmental organizations, including the World Resources Institute and Ceres, are calling on US financial regulators to urgently address climate-related financial risks. They highlight a report by the Commodity Futures Trading Commission (CFTC) which identifies risks stemming from climate-driven damage to infrastructure and assets, as well as the failure of financial institutions to adapt to a net-zero-carbon transition.
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Document type: Statement
Never waste a crisis: How sub-Saharan African insurers are being affected by, and are responding to, COVID-19
The report examines how COVID-19 disrupted the sub-Saharan African insurance value chain, forcing rapid digitalisation and straining balance sheets due to reduced premium income and investment returns. While household life and health policies generally covered the pandemic, business interruption insurance largely did not due to global reinsurance exclusions. The document highlights opportunities for insurers to adopt remote onboarding and for regulators to remove barriers to digital sales and manage potential market consolidation.
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Document type: Report
ECB’s coronavirus prescription overlooks social and environmental ills
The document criticizes the European Central Bank (ECB) for implementing coronavirus relief measures that primarily benefit large, polluting companies and banks rather than small businesses and households. It highlights that quantitative easing and loan facilities lack criteria to target the most vulnerable and fail to account for carbon impacts or climate risks in collateral. Additionally, the author argues that the relaxation of prudential rules and the postponement of European stress tests weaken financial risk prevention and increase the systemic risk posed by carbon assets.
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Document type: Statement
Banques centrales et monnaie climat
The document argues that central banks, particularly the European Central Bank (ECB), are failing to address the climate emergency despite their power to influence the financing of polluting versus green activities. It claims the ECB actively supports polluters through collateral frameworks and Quantitative Easing, which benefit fossil fuel and coal companies. While noting a growing awareness within the NGFS and the Banque de France, the text demands an immediate end to the financing of climate-destructive assets to ensure financial stability and meet European climate goals.
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Document type: Statement
Open letter to Bank of England's Andrew Bailey
The letter argues that the financial system currently supports emissions leading to warming exceeding 4C, posing catastrophic risks to banks and insurers. While acknowledging the Bank of England's existing work on climate risk stress tests and disclosures, the signatories assert these measures are insufficient due to short time horizons and methodological limitations. They propose three specific actions: making climate-related disclosures mandatory, excluding fossil fuel assets (starting with coal) from future bond purchases and collateral frameworks, and adjusting the macroprudential framework to increase capital requirements for high-carbon loans.
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Document type: Statement
RE: Oppose Unless Amended - SB488 (Bradford)
A coalition of environmental and advocacy organizations opposes an amendment to California SB 488 that would limit the Insurance Commissioner's ability to conduct data calls and surveys. The authors argue that restricting this authority, specifically the provision limiting data calls to activity within California, would undermine the state's ability to monitor material financial risks associated with climate change and the transition to a low-carbon economy, effectively ending initiatives like the Climate Risk Carbon Initiative.
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Document type: Statement
sei_vanguard_letter_apr26_scan-d4f66909dd427c7a.pdf
The Stockholm Environment Institute U.S. has called on Vanguard to move away from a passive approach to shareholder voting regarding climate risk. The letter argues that the transition to a low-carbon economy, consistent with a 2 degrees C warming limit, poses material risks to the business models of fossil fuel companies like Exxon Mobil, Chevron, and ConocoPhillips. It highlights that these companies are not systematically disclosing such risks, which could lead to stranded assets and market volatility. Consequently, the institute requests that Vanguard require its invested companies to provide annual disclosures on climate and transition risks.
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Document type: Statement
REPORT ON THE THEORY OF RISK AS A SOCIETAL SECURITY INSTRUMENT
The report examines the intersection of financial systems and societal security, arguing that both fields have historically relied on probabilistic risk models but are shifting toward managing 'radical uncertainty'. It details various financial risk models—such as Modern Portfolio Theory, CAPM, and Value at Risk (VaR)—and contrasts them with security methodologies like scenario planning and pre-emption. The author concludes that the 'financialisation of security' and 'securitisation of finance' reflect a broader liberal security problematic of securing circulation in a complex, interdependent world, where societal security is increasingly defined by qualitative resilience and preparedness rather than quantified prediction.
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Document type: Report
The BRICS Contingent Reserve Arrangement and its Position in the Emerging Global Financial Architecture
The BRICS Contingent Reserve Arrangement (CRA) is currently viewed as a symbolic initiative rather than a substantive challenger to the IMF due to its limited size and reliance on IMF-linked conditionality. Established with a $100 billion pool, the CRA provides liquidity and precautionary instruments to address short-term balance of payments pressures. However, 70% of requested funds are 'IMF-linked', requiring a conditionality-based agreement with the IMF, which the authors argue undermines the CRA's purpose as a counterweight to Western-dominated institutions. Drawing on the evolution of the Chiang Mai Initiative Multilateralization (CMIM), the document recommends that the CRA establish its own macroeconomic surveillance facility, increase commitment sizes, and reduce or eliminate the IMF-linked portion to ensure participating countries' independence.
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Document type: Policy brief
EU financial reforms: an unfinished business
The author argues that EU financial reforms since 2008 are a cyclical response to public anger rather than a structural paradigm shift. While the CRDIV package, the Single Supervisory Mechanism (SSM), and the Bank Recovery and Resolution Directive (BRRD) represent progress, the document highlights critical gaps: the lack of a binding leverage ratio, insufficient transparency and accountability for the European Central Bank, and loopholes allowing 'preventive' public recapitalisation of banks. Regarding derivatives, the author contends that the EMIR and MiFID II frameworks may be counterproductive, potentially creating new 'too big to fail' risks through central counterparties and failing to effectively limit speculation in commodity markets. The paper concludes that the EU relies too heavily on transparency and needs a radical shift toward simpler, more stringent rules, such as the mandatory separation of high-risk banking activities.
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Document type: Research paper
The G-20 and Financial Regulation in Africa
The document examines the intersection of G-20 financial regulatory initiatives and African economic development. It identifies five key G-20 focus areas—financial stability, financial inclusion, local currency bond markets, agricultural finance, and trade finance—and assesses the mechanisms through which non-member African states can influence these global standards. While acknowledging that the G-20 recognizes the needs of developing countries, the author argues that African representation remains limited and that the adoption of international standards like Basel II/III must be sequenced to align with local developmental goals.
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Document type: Policy brief
The Interconnections Between Islamic Finance and Sustainable Finance
The report examines the systemic failures of conventional finance, specifically citing the Enron bankruptcy, the subprime mortgage crisis, and the Greek debt crisis, as evidence of the dangers of excessive leverage and opaque derivatives. It proposes Islamic finance as a sustainable alternative, grounded in Sharia principles such as the prohibition of riba (interest), gharar (uncertainty), and maisir (speculation). The author argues that the Islamic requirement for asset-backed financing and profit-loss sharing aligns financial incentives with the real economy, potentially preventing the types of market failures seen in conventional banking.
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Document type: Report
The Regulation and Supervision of Microfinance: Main issues and progress
The document examines the necessity and challenges of regulating microfinance, particularly as the sector shifts toward commercialization and deposit-taking. It argues against a 'one-size-fits-all' approach, suggesting that prudential and consumer protection rules must be adapted to the specific risks of microfinance, such as unsecured lending and high operational costs. Using Indonesia's experience, it highlights the importance of independent oversight and the transition from enabling deregulation to corrective legislation.
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Document type: Policy brief
Financial Stability and Systemic Risk: Lenses and Clocks
The report advocates for a re-engineering of the global financial system by applying sustainable finance principles to mitigate systemic risk. It proposes the use of 'lenses' for a more granular understanding of diverse risks and 'clocks' to balance short-term quantifiable risks with long-term 'creeping risks'. The document identifies six critical areas for reform: over-the-counter markets, institutional investor accountability, stock exchange listing requirements, Basel Committee banking risk, credit rating agencies, and Solvency II insurance stability.
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Document type: Report