Note: The following is the introduction from RiskSpan’s contribution to a series of essays on Climate Risk and the Housing Market published this month by the Mortgage Bankers Association’s Research Institute for Housing America.
Global temperatures will continue to increase over the next 50 years regardless of the actions people and governments take. The impacts of that warming are expected to accumulate and become more severe and frequent over time, causing stress throughout our economy. Regulators are clearly signaling that climate risk analysis will need to become a regular part of risk management activities. But detailed, industry-specific guidance has not been defined. FHFA and the regulated entities have yet to release a climate risk framework. They clearly recognize the threat to the housing finance system, however, and are actively working towards accounting for these risks.
Most executives and boards have become conceptually familiar with the physical and transition risks of climate change. But significant questions remain around how these concepts translate into specific, quantifiable business, asset, regulatory, legal, and reputation risks in the housing finance industry. Further complicating matters, climate science continues to evolve and there is limited historical data to understand how the effects of climate change will trickle into the housing market.
Sean Becketti1 describes the myriad ways climate change and natural hazard risk can permeate the housing and housing finance industries as well as some of the ways to mitigate its effects. However, quantifying these risks and inserting them into mortgage credit and prepayment models comes with significant challenges. No “best practices” have emerged for incorporating these into traditional model frameworks.
This paper puts forth a practical framework to incorporate climate risk into existing enterprise risk management practices for the housing finance industry. The framework incorporates suggestions to prepare for coming regulatory requirements on climate risk and, more importantly, proactively managing and mitigating this risk. Our approach is based on over two years of research and field work RiskSpan has conducted with its clients, and the resulting models RiskSpan has developed to deliver insights into these risks.
The paper is organized into two main sections:
- Prescribed Climate Scenarios and Emerging Regulatory Requirements
- A Practical Approach to Climate Risk Assessment for Mortgage Finance
Layering climate risk into enterprise risk management is likely to be a multiyear process. This paper focuses on steps to take in the initial one to two years after climate risk has been prioritized for investment of time and resources by corporate leadership. As explained in an MBA white paper from June 2022,2 “Existing risk management practices, structures, and relationships are already capturing potential risks from climate change.” The aim of this paper is to investigate specific ways in which existing credit, operational, and market risk frameworks can be leveraged to address this challenge, rather than seeking to reinvent the wheel.