ESG—it is the hottest topic in our space. No conference or webinar is complete without a panel touting the latest ESG bond or the latest advance in reporting and certification. What a lot of these pieces neglect to address is the complicated relationship between the “E” and the “S” of ESG. In particular, that climate-risk exposed properties are also often properties in underserved communities, providing much-needed affordable housing to the country.
Last week, the White House issued an Executive Order of Climate-Related Financial Risk. The focus of the order was to direct government agencies toward both disclosure and mitigation of climate-related financial risk. The order reinforces the already relentless focus on ESG initiatives within our industry. The order specifically calls on the USDA, HUD, and the VA to ‘consider approaches to better integrate climate-related financial risk into underwriting standards, loan terms and conditions, and asset management and servicing procedures, as related to their Federal lending policies and programs.” Changes here will likely presage changes by the GSEs.
In mortgage finance, some of the key considerations related to disclosure and mitigation are as follows:
Disclosure of Climate-Related Financial Risk:
- Homes exposed to increasing occurrence to natural hazards due to climate changes.
- Homes exposed to the risk of decreasing home prices due to climate change, because of either increasing property insurance costs (or un-insurability) or localized transition risks of industry-exposed areas (e.g., Houston to the oil and gas industry).
Mitigation of Climate-Related Financial Risk:
- Reducing the housing industry’s contribution to greenhouse gas emissions in alignment with the president’s goal of a net-zero emissions economy by 2050. For example, loan programs that support retrofitting existing housing stock to reduce energy consumption.
- Considering a building location’s exposure to climate-related physical risk. Directing investment away for areas exposed to the increasing frequency and severity of natural disasters.
But products and programs that aim to support the goal of increased disclosure and mitigation of climate-related financial risk can create situations in which underserved communities disproportionately bear the costs of our nation’s pivot toward climate resiliency. The table below connects the FEMA’s National Risk Index data to HUD’s list of census tracts that qualify for low-income housing tax credits, which HUD defines as tracts that have ‘50 percent of households with incomes below 60 percent of the Area Median Gross Income (AMGI) or have a poverty rate of 25 percent or more.’ Census tracts with the highest risk of annual loss from natural disaster events are disproportionally made of HUD’s Qualified Tracts.
As an industry, it’s important to remember that actions taken to mitigate exposure to increasing climate-related events will always have a cost to someone. These costs could be in the form of increased insurance premiums, decreasing home prices, or even loss of affordable housing options altogether. All this is not to say that action should not be taken, only that balancing social ESG goals should also be considered when ambitious environmental ESG goals come at their expense.
The White House identified this issue right at the top of the order by indicating that any action on the order would need to account for ‘disparate impacts on disadvantaged communities and communities of color.’
“It is therefore the policy of my Administration to advance consistent, clear, intelligible, comparable, and accurate disclosure of climate-related financial risk (consistent with Executive Order 13707 of September 15, 2015 (Using Behavioral Science Insights to Better Serve the American People), including both physical and transition risks; act to mitigate that risk and its drivers, while accounting for and addressing disparate impacts on disadvantaged communities and communities of color (consistent with Executive Order 13985 of January 20, 2021 (Advancing Racial Equity and Support for Underserved Communities Through the Federal Government)) and spurring the creation of well-paying jobs; and achieve our target of a net-zero emissions economy by no later than 2050.”
The social impacts of any environmental initiative need to be considered. Steps should be taken to avoid having the cost of changes to underwriting processes and credit policies be disproportionately borne by underserved and vulnerable communities. To this end, a balanced ESG policy will ultimately require input from stakeholders across the mortgage industry.
