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Articles Tagged with: Climate

An Emerging Climate Risk Consensus for Mortgages?

That climate change poses a growing—and largely unmeasured—risk to housing and mortgage investors is not news. As is often the case with looming threats whose timing and magnitude are only vaguely understood, increased natural hazard risks have most often been discussed anecdotally and in broad generalities. This, however, is beginning to change as the reality of these risks becomes increasingly clear to an increasing number of market participants and industry-sponsored research begins to emerge.

This past week’s special report by the Mortgage Bankers Association’s Research Institute for Housing America, The Impact of Climate Change on Housing and Housing Finance, raises a number of red flags about our industry’s general lack of preparedness and the need for the mortgage industry to take climate risk seriously as a part of a holistic risk management framework. Clearly this cannot happen until appropriate risk scenarios are generated and introduced into credit and prepayment models.

One of the puzzles we are focusing on here at RiskSpan is an approach to creating climate risk stress testing that can be easily incorporated into existing mortgage modeling frameworks—at the loan level—using home price projections and other stress model inputs already in use. We are also partnering with firms who have been developing climate stress scenarios for insurance companies and other related industries to help ensure that the climate risk scenarios we create are consistent with the best and most recently scientific research available.

Also on the short-term horizon is the implementation of FEMA’s new NFIP premiums for Risk Rating 2.0. Phase I of this new framework will begin applying to all new policies issued on or after October 1, 2021. (Phase II kicks in next April.) We wrote about this change back in February when these changes were slated to take effect back in the spring. Political pressure, which delayed the original implementation may also impact the October date, of course. We’ll be keeping a close eye on this and are preparing to help our clients estimate the likely impact of FEMA’s new framework on mortgages (and the properties securing them) in their portfolios.

Finally, this past week’s SEC statement detailing the commission’s expectations for climate-related 10-K disclosures is also garnering significant (and warranted) attention. By reiterating existing guidelines around disclosing material risks and applying them specifically to climate change, the SEC is issuing an unmistakable warning shot at filing companies who fail to take climate risk seriously in their disclosures.

Contact us (or just email me directly if you prefer) to talk about how we are incorporating climate risk scenarios into our in-house credit and prepayment models and how we can help incorporate this into your existing risk management framework.  



Climate Terms the Housing Market Needs to Understand

The impacts of climate change on housing and holders of mortgage risk are very real and growing. As the frequency and severity of perils increases, so does the associated cost – estimated to have grown from $100B in 2000 to $450B 2020 (see chart below). Many of these costs are not covered by property insurance, leaving homeowners and potential mortgage investors holding the bag. Even after adjusting for inflation and appreciation, the loss to both investors and consumers is staggering. 

Properly understanding this data might require adding some new terms to your personal lexicon. As the housing market begins to get its arms around the impact of climate change to housing, here are a few terms you will want to incorporate into your vocabulary.

  1. Natural Hazard

In partnership with climate modeling experts, RiskSpan has identified 21 different natural hazards that impact housing in the U.S. These include familiar hazards such as floods and earthquakes, along with lesser-known perils, such as drought, extreme temperatures, and other hydrological perils including mudslides and coastal erosion. The housing industry is beginning to work through how best to identify and quantify exposure and incorporate the impact of perils into risk management practices more broadly. Legacy thinking and risk management would classify these risks as covered by property insurance with little to no downstream risk to investors. However, as the frequency and severity increase, it is becoming more evident that risks are not completely covered by property & casualty insurance.

We will address some of these “hidden risks” of climate to housing in a forthcoming post.

  1. Wildland Urban Interface

The U.S. Fire Administration defines Wildland Urban Interface as “the zone of transition between unoccupied land and human development. It is the line, area, or zone where structures and other human development meet or intermingle with undeveloped wildland or vegetative fuels.” An estimated 46 million residences in 70,000 communities in the United States are at risk for WUI fires. Wildfires in California garner most of the press attention. But fire risk to WUIs is not just a west coast problem — Florida, North Carolina and Pennsylvania are among the top five states at risk. Communities adjacent to and surrounded by wildland are at varying degrees of risk from wildfires and it is important to assess these risks properly. Many of these exposed homes do not have sufficient insurance coverage to cover for losses due to wildfire.

  1. National Flood Insurance Program (NFIP) and Special Flood Hazard Area (SFHA)

The National Flood Insurance Program provides flood insurance to property owners and is managed by the Federal Emergency Management Agency (FEMA). Anyone living in a participating NFIP community may purchase flood insurance. But those in specifically designated high-risk SFPAs must obtain flood insurance to obtain a government-backed mortgage. SFHAs as currently defined, however, are widely believed to be outdated and not fully inclusive of areas that face significant flood risk. Changes are coming to the NFIP (see our recent blog post on the topic) but these may not be sufficient to cover future flood losses.

  1. Transition Risk

Transition risk refers to risks resulting from changing policies, practices or technologies that arise from a societal move to reduce its carbon footprint. While the physical risks from climate change have been discussed for many years, transition risks are a relatively new category. In the housing space, policy changes could increase the direct cost of homeownership (e.g., taxes, insurance, code compliance, etc.), increase energy and other utility costs, or cause localized employment shocks (i.e., the energy industry in Houston). Policy changes by the GSEs related to property insurance requirements could have big impacts on affected neighborhoods.

  1. Physical Risk

In housing, physical risks include the risk of loss to physical property or loss of land or land use. The risk of property loss can be the result of a discrete catastrophic event (hurricane) or of sustained negative climate trends in a given area, such as rising temperatures that could make certain areas uninhabitable or undesirable for human housing. Both pose risks to investors and homeowners with the latter posing systemic risk to home values across entire communities.

  1. Livability Risk

We define livability risk as the risk of declining home prices due to the desirability of a neighborhood. Although no standard definition of “livability” exists, it is generally understood to be the extent to which a community provides safe and affordable access to quality education, healthcare, and transportation options. In addition to these measures, homeowners also take temperature and weather into account when choosing where to live. Finding a direct correlation between livability and home prices is challenging; however, an increased frequency of extreme weather events clearly poses a risk to long-term livability and home prices.

Data and toolsets designed explicitly to measure and monitor climate related risk and its impact on the housing market are developing rapidly. RiskSpan is at the forefront of developing these tools and is working to help mortgage credit investors better understand their exposure and assess the value at risk within their businesses.

Contact us to learn more.



Why Mortgage Climate Risk is Not Just for Coastal Investors

When it comes to climate concerns for the housing market, sea level rise and its impacts on coastal communities often get top billing. But this article in yesterday’s New York Times highlights one example of far-reaching impacts in places you might not suspect.

Chicago, built on a swamp and virtually surrounded by Lake Michigan, can tie its whole existence as a city to its control and management of water. But as the Times article explains, management of that water is becoming increasingly difficult as various dynamics related to climate change are creating increasingly large and unpredictable fluctuations in the level of the lake (higher highs and lower lows). These dynamics are threatening the city with more frequency and severe flooding.

The Times article connects water management issues to housing issues in two ways: the increasing frequency of basement flooding caused by sewer overflow and the battering buildings are taking from increased storm surge off the lake. Residents face increasing costs to mitigate their exposure and fear the potentially negative impact on home prices. As one resident puts it, “If you report [basement flooding] to the city, and word gets out, people fear it’s going to devalue their home.”

These concerns — increasing peril exposure and decreasing valuations — echo fears expressed in a growing number of seaside communities and offer further evidence that mortgage investors cannot bank on escaping climate risk merely by avoiding the coasts. Portfolios everywhere are going to need to begin incorporating climate risk into their analytics.



Hurricane Season a Double-Whammy for Mortgage Prepayments

As hurricane (and wildfire) season ramps up, don’t sleep on the increase in prepayment speeds after a natural disaster event. The increase in delinquencies might get top billing, but prepays also increase after events—especially for homes that were fully insured against the risk they experienced. For a mortgage servicer with concentrated geographic exposure to the event area, this can be a double-whammy impacting their balance sheet—delinquencies increase servicing advances, prepays rolling loans off the book. Hurricane Katrina loan performance is a classic example of this dynamic.



In ESG Policy, ‘E’ Should Not Come at the Expense of ‘S’

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.


Flood Insurance Changes: What Mortgage Investors Need to Know

Major changes are coming to FEMA’s National Flood Insurance Program on April 1st2021, the impacts of which will reverberate throughout real estate, mortgage, and structured finance markets in a variety of ways. 

For years, the way the NFIP has managed flood insurance in the United States has been the subject of intense scrutiny and debateCompounding the underlying moral hazard issues raised by the fact that taxpayers are subsidizing homeowners who knowingly move into flood-prone areas is the reality that the insurance premiums paid by these homeowners collectively are nowhere near sufficient to cover the actual risks faced by properties in existing flood zones. 

Climate change is only exacerbating the gap between risk and premiums. According to research released this week by First Street Foundation, the true economic risk is 3.7 times higher than the level at which the NFIP is currently pricing flood insurance. And premiums would need to increase by 7 times to cover the expected economic risk in 2051. 

New York Times article this week addresses some of the challenges (political and otherwise) a sudden increase in flood insurance premiums would create. These include existing homeowners no longer being able to afford the higher monthly payments as well as a potential drop in property values in high-risk areas as the cost of appropriately priced flood insurance is priced in. These risks are also of concern to mortgage investors who obviously have little interest in seeing sudden declines in the value of properties that secure the mortgages they own. 

Notwithstanding these risks, the NFIP recognizes that the disparity between true risk and actual premiums cannot continue to go unaddressed. The resulting adjustment to the way in which the NFIP will calculate premiums – called Risk Rating 2.0  will reflect a policy of phasing out subsidies (wherein lower-risk dwellings absorb the cost of those in the highest-risk areas) and tying premiums to thactual flood risk of a given structure. 

Phase-In 

The specific changes to be announced on April 1st will go into effect on October 1st, 2021. But the resulting premium increases will not happen all at once. Annual limits currently restrict how fast premiums can increase for primary residences, ranging from 5%-18% per year. (Non-primary residences have a cap of 25%). FEMA has not provided much guidance on how these caps will apply under Risk Rating 2.0 other than to say that all properties will be on a glide path to actuarial rates.” The caps, however, are statutory and would require an act of Congress to change. And Members of Congress have shown reluctance in the past to saddle their constituents with premium spikes. 

Phasing in premium increases helps address the issue of affordability for current homeowners. This is equally important to investors who hold these existing homeowners’ mortgages. It does not however, address the specter of significant property value declines because the sale of the home has historically caused the new, fully priced premium to take effect for the next homeowner. It has been suggested that FEMA could blunt this problem by tying insurance premiums to properties rather than to homeowners. This would enable the annual limits on price increases to remain in effect even if the house is sold. 

Flood Zones & Premiums 

Despite a widely held belief that flood zone maps are out of date and that climate change is hastening the need to redraw them, Risk Rating 2.0 will reportedly apply only to homes located in floodplains as currently defined. Premium calculations, however, will focus on the geographical and structural features of a particular home, including foundation type and replacement cost, rather than on a property’s location within a flood zone.  

The Congressional Research Service’s paper detailing Risk Rating 2.0 acknowledges that premiums are likely to go up for many properties that are currently benefiting from subsidies. The paper emphasizes that it is not in FEMA’s authority to provide affordability programs and that this is a job for Congress as they consider changes to the NFIP. 

“FEMA does not currently have the authority to implement an affordability program, nor does FEMA’s current rate structure provide the funding required to support an affordability program. However, affordability provisions were included in the three bills which were introduced in the 116th Congress for long-term reauthorization of the NFIP: the National Flood Insurance Program Reauthorization Act of 2019 (H.R. 3167), and the National Flood Insurance Program Reauthorization and Reform Act of 2019 (S. 2187) and its companion bill in the House, H.R. 3872. As Congress considers a long-term reauthorization of the NFIP, a central question may be who should bear the costs of floodplain occupancy in the future and how to address the concerns of constituents facing increases in flood insurance premiums.” 

Implications for Homeowners and Mortgage Investors 

FEMA is clearly signaling that NFIP premium increases are coming. Any increases to insurance premiums will impact the value of affected homes in much the same way as rising interest rates. Both drive prices down by increasing monthly payments and thus reducing the purchasing power of would-be buyers. The difference, however, is that while interest rates affect the entire housing market, this change will be felt most acutely by owners of properties in FEMA’s Special Flood Hazard Areas that require insurance. The severity of these impacts will clearly be related to the magnitude of the premium increases, whether increase caps will be applied to properties as well as owners, and the manner in which these premiums get baked into sales prices. 

Mortgage risk holders need to be ready to assess their exposure to these flood zone properties and the areas that see the biggest rate jumps. The simplest way to do this is through HPI scenarios based on a consistent view of the ‘affordability’ of the house  i.e., by adjusting the maximum mortgage payment for a property downward to compensate for the premium increase and then solving for the drag on home price.


Get in touch with us for a no-obligation discussion on how to measure the impact of these forthcoming changes on your portfolio. We’d be interested in hearing your insights as well. 


Overcoming Data Limitations (and Inertia) to Factor Climate into Credit Risk Modeling

With each passing year, it is becoming increasingly clear to mortgage credit investors that climate change is emerging as a non-trivial risk factor that must be accounted for. Questions around how precisely to account for this risk, however, and who should ultimately bear it, remain unanswered. 

Current market dynamics further complicate these questionsLate last year, Politico published this special report laying out the issues surrounding climate risk as it relates to mortgage finance. Even though almost everyone agrees that underinsured natural disaster risk is a problem, the Politico report outlines several forces that make it difficult for anyone to do anything about it. The massive undertaking of bringing old flood zone maps up to date is just one exampleAs Politico puts it: 

The result, many current and former federal housing officials acknowledge, is a peculiar kind of stasis — a crisis that everyone sees coming but no one feels empowered to prevent, even as banks and investors grow far savvier about assessing climate risk. 

At some point, however, we will reach a tipping point – perhaps a particularly devastating event (or series of events) triggering significant losses. As homeowners, the GSEs, and other mortgage credit investors point fingers at one another (and inevitably at the federal government) a major policy update will become necessary to identify who ultimately bears the brunt of mispriced climate risk in the marketOnce quantified and properly assigned, the GSEs will price in climate risk in the same way they bake in other contributors to credit risk — via higher guarantee fees. For non-GSE (and CRT) loans, losses will continue to be borne by whoever holds the credit risk 

Recognizing that such an event may not be far off, the GSEs, their regulator, and everyone else with credit exposure are beginning to appreciate the importance of understanding the impact of climate events on mortgage performance. This is not easily inferred from the historical data record, however. And those assessing risk need to make informed assumptions about how historically observed impacts will change in the future. 

The first step in constructing these assumptions is to compile a robust historical dataset. To this end, RIskSpan began exploring the impact of certain hurricanes a few years ago. This initial analysis revealed a significant impact on short-term mortgage delinquency rates (not surprisingly), but less of an impact on default rates. In other words, affected borrowers encountered hardship but ultimately recovered. 

This research is preliminary, however, and more data will be necessary to build scenario assumptions as climate events become more severe and widespread. As more data covering more events—including wildfires—becomes available, RiskSpan is engaged in ongoing research to tease out the impact each of these events has on mortgage performance.  

It goes without saying that climate scenario assumptions need to be grounded in reality to be useful to credit investors. Because time-series data relationships are not always detectable using conventional means, especially when data is sparse, ware beginning to see promise in leveraging various machine learning techniques to this endWe believe this historical, machine-learning-based research will provide the backbone for an approach that merges historical effects of events with inputs about the increasing frequency and severity of these events as they become better understood and more quantifiable. 

Precise forecasting of severe climate events by zip code in any given year is not here yet. But an increasingly reliable framework for gauging the likely impact of these events on mortgage performance is on the horizon.  


The NRI: An Emerging Tool for Quantifying Climate Risk in Mortgage Credit

Climate change is affecting investment across virtually every sector in a growing number of mostly secondary ways. Its impact on mortgage credit investors, however, is beginning to be felt more directly.

Mortgage credit investors are investors in housing. Because housing is subject to climate risk and borrowers whose houses are destroyed by natural disasters are unlikely to continue paying their mortgages, credit investors have a vested interest in quantifying the risk of these disasters.

To this end, RiskSpan is engaged in leveraging the National Risk Index (NRI) to assess the natural disaster and climate risk exposure of mortgage portfolios.

This post introduces the NRI data in the context of mortgage portfolio analysis (loans or mortgage-backed securities), including what the data contain and key considerations when putting together an analysis. A future post will outline an approach for integrating this data into a framework for scenario analysis that combines this data with traditional mortgage credit models.

The National Risk Index

The National Risk Index (NRI) was released in October 2020 through a collaboration led by FEMA. It provides a wealth of new geographically specific data on natural hazard risks across the country. The index and its underlying data were designed to help local governments and emergency planners to better understand these risks and to plan and prepare for the future.

The NRI provides information on both the frequency and severity of natural risk events. The level of detailed underlying data it provides is astounding. The NRI focuses on 18 natural risks (discussed below) and provides detailed underlying components for each. The severity of an event is broken out by damage to buildings, agriculture, and loss of life. This breakdown lets us focus on the severity of events relative to buildings. While the definition of building here includes all types of real estate—houses, commercial, rental, etc.—having the breakdown provides an extra level of granularity to help inform our analysis of mortgages.

The key fields that provide important information for a mortgage portfolio analysis are bulleted below. The NRI provides these data points for each of the 18 natural hazards and each geography they include in their analysis.

  • Annualized Event Frequency
  • Exposure to Buildings: Total dollar amount of exposed buildings
  • Historical Loss Ratio for Buildings (Bayesian methods to derive this estimate, such that every geography is covered for its relevant risks)
  • Expected Annual Loss for Buildings
  • Population estimates (helpful for geography weighting)

Grouping Natural Disaster Risks for Mortgage Analysis

The NRI data covers 18 natural hazards, which pose varying degrees of risk to housing. We have found the framework below to be helpful when considering which risks to include in an analysis. We group the 18 risks along two axes:

1) The extent to which an event is impacted by climate change, and

2) An event’s potential to completely destroy a home.

Earthquakes, for example, have significant destructive potential, but climate change is not a major contributor to earthquakes. Conversely, heat waves and droughts wrought by climate change generally do not pose significant risk to housing structures.

When assessing climate risk, RiskSpan typically focuses on the five natural hazard risks in the top right quadrant below.

Immediate Event Risk versus Cumulative Event Risk

Two related but distinct risks inform climate risk analysis.

  1. Immediate Event Analysis: The risk of mortgage delinquency and default resulting directly from a natural disaster eventhome severely damaged or destroyed by a hurricane, for example.  
  2. Cumulative Event Risk: Less direct than immediate event risk, this is the risk of widespread home price declines across an entire area communities because of increasing natural hazard risk brought on by climate changeThese secondary effects include: 
    • Heightened homebuyer awareness or perception of increasing natural hazard risk,
    • Property insurance premium increases or areas becoming ‘self-insured, 
    • Government policy impacts (e.g., potential flood zone remapping), and 
    • Potential policy changes related to insurance from key players in the mortgage market (i.e., Fannie Mae, Freddie Mac, FHFA, etc.). 

NRI data provides an indication of the probability of immediate event occurrence and its historic severity in terms of property losses. We can also empirically observe historical mortgage performance in the wake of previous natural disaster events. Data covering several hurricane and wildfire events are available.

Cumulative event risk is less observable. A few academic papers attempt to tease out these impacts, but the risk of broader home price declines typically needs to be incorporated into a risk assessment framework through transparent scenario overlays. Examples of such scenarios include home price declines of as much as 20% in newly flood-exposed areas of South Florida. There is also research suggesting that there are often long term impacts to consumer credit following a natural disaster 

Geography Normalization

Linking to the NRI is simple when detailed loan pool geographic data are available. Analysts can merge by census tract or county code. Census tract is the more geographically granular measure and provides a more detailed analysis.

For many capital markets participants, however, that level of geographic specific detail is not available. At best, an investor may have a 5-digit or 3-digit zip code. Zip codes do not directly match to a given county or census tract and can potentially span across those distinctions.

There is no perfect way to perform the data link when zip code is the only available geographic marker. We take an approach that leverages the other data on housing stock by census tract to weight mortgage portfolio data when multiple census tracts map to a zip code.

Other Data Limitations

The loss information available represents a simple historical average loss rate given an event. But hurricanes (and hurricane seasons) are not all created equal. The same is true of other natural disasters. Relying on averages may work over long time horizons but could significantly underpredict or overpredict loss in a particular year. Further, the frequency of events is rising so that what used to be considered 100 year event may be closer to a 10 or 20 year event. Lacking data about what losses might look like under extreme scenarios makes modeling such events problematic.

The data also make it difficult to take correlation into account. Hurricanes and coastal flooding are independent events in the dataset but are obviously highly correlated with one another. The impact of a large storm on one geographic area is likely to be correlated with that of nearby areas (such as when a hurricane makes its way up the Eastern Seaboard).

The workarounds for these limitations have limitations of their own. But one solution involves designing transparent assumptions and scenarios related to the probability, severity, and correlation of stress events. We can model outlier events by assuming that losses for a particular peril follow a normal distribution with set standard deviations. Other assumptions can be made about correlations between perils and geographies. Using these assumptions, stress scenarios can be derived by picking a particular percentile along the loss distribution.

A Promising New Credit Analysis Tool for Mortgages

Notwithstanding its limitations, the new NRI data is a rich source of information that can be leveraged to help augment credit risk analysis of mortgage and mortgage-backed security portfolios. The data holds great promise as a starting point (and perhaps more) for risk teams starting to put together climate risk and other ESG analysis frameworks.


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