SJR113 is a joint resolution under chapter 8 of title 5 (the Congressional Review Act) that disapproves the Office of the Comptroller of the Currency’s rule titled “Rescission of Principles for Climate-Related Financial Risk Management for Large Financial Institutions” (90 Fed. Reg. 51756; Nov. 18, 2025).
The resolution states that the rescission rule has no force or effect.
If enacted, the resolution would stop the OCC’s formal removal of those Principles and thereby preserve the supervisory expectations the OCC previously set out for large national banks and federal savings associations on assessing and managing climate-related financial risks. The resolution also invokes legal limits on reissuing a substantially similar rule under the Congressional Review Act, constraining how the OCC could achieve the same rescission in the near term.
At a Glance
What It Does
The joint resolution invokes the Congressional Review Act to disapprove and nullify a specific OCC rule that rescinded supervisory Principles on climate-related financial risk for large institutions. It declares that the named rule "shall have no force or effect."
Who It Affects
The resolution directly affects the OCC, large national banks and federal savings associations supervised by the OCC, their compliance and risk-management teams, and market participants who rely on consistent federal supervisory expectations for climate-related risk. It also bears on other federal and state regulators that coordinate supervision or align expectations.
Why It Matters
This is a procedural but consequential intervention: nullifying a rescission preserves a regulatory stance on climate risk without creating new statutory obligations, and it limits the OCC’s ability to reissue the same rescission under the terms of the CRA. The outcome shapes supervisory practice and firms’ compliance planning for climate-related financial risks.
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What This Bill Actually Does
SJR113 targets one discrete regulatory action: the OCC’s rule to rescind the agency’s earlier "Principles for Climate-Related Financial Risk Management for Large Financial Institutions." The resolution does not rewrite bank law or create new statutory duties; it simply uses the Congressional Review Act to say the rescission rule has no force or effect. In practice, that prevents the OCC’s rescission from taking legal effect and keeps the status quo supervisory materials in place unless and until a different lawful change occurs.
The Congressional Review Act (CRA) provides a fast-track mechanism for Congress to void recently issued agency rules. When Congress disapproves a rule under the CRA, that rule is nullified and the agency faces a constraint against reissuing a rule in “substantially the same” form without new authorization.
SJR113 therefore does more than shelve the rescission temporarily: it creates a statutory barrier against a near-term reissue of an identical rescission by the OCC.Because the original Principles were supervisory guidance rather than a statutory or regulatory requirement codified by Congress, nullifying the rescission primarily affects supervisory expectations and examination practice rather than adding criminal or civil penalties. Banks subject to OCC supervision would continue to operate under the expectations embodied in the Principles unless the OCC, another federal regulator, or Congress takes a separate action to change those expectations.
The practical effect will play out in examinations, enforcement discretion, and firms’ risk management and disclosures.
The Five Things You Need to Know
SJR113 disapproves and nullifies the OCC’s rule titled “Rescission of Principles for Climate-Related Financial Risk Management for Large Financial Institutions.”, The resolution cites the Federal Register publication for the rescission: 90 Fed. Reg. 51756 (Nov. 18, 2025).
The resolution proceeds under the Congressional Review Act (chapter 8 of title 5), which makes the named rule have "no force or effect.", If enacted, the CRA consequence includes a bar on reissuing a substantially similar rule without subsequent congressional authorization, limiting the OCC’s near-term options.
The measure affects supervisory guidance (the OCC’s Principles) rather than creating new statutory banking obligations; its effect is to preserve supervisory expectations and examination benchmarks.
Section-by-Section Breakdown
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Statement of purpose and enabling authority
The opening lines identify the joint resolution as taken under chapter 8 of title 5, the Congressional Review Act. That choice of authority governs both the legal effect of the resolution and the procedural consequences for the agency, including the bar on substantially similar reissuance. The bill does not add regulatory text or amend banking statutes; it relies entirely on the CRA’s mechanism.
Disapproval and nullification of the OCC rescission rule
The operative clause disapproves the specific OCC rule and states that the rescission "shall have no force or effect." Practically, this nullification prevents the rescission from taking legal effect and preserves the pre-existing regulatory posture that the rescission sought to change. The clause is deliberately narrow: it addresses one rule by citation rather than asserting broader policy.
Narrow scope, with CRA reissuance constraint
Because the resolution invokes the CRA, its reach is limited to the named rule and to the statutory mechanics of the CRA. The CRA also imposes a prohibition on an agency’s ability to reissue a rule in substantially the same form without subsequent congressional action. The resolution does not direct the OCC to take any affirmative steps beyond the nullification, nor does it modify any other agencies’ guidance or supervision.
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Explore Finance in Codify Search →Who Benefits and Who Bears the Cost
Every bill creates winners and losers. Here's who stands to gain and who bears the cost.
Who Benefits
- Climate-focused investors and asset managers: They gain greater predictability that OCC supervisory expectations regarding climate-related risk will remain part of the supervisory landscape, which supports integration of climate risk into risk assessments and investment decisions.
- Community groups and counterparties concerned about systemic climate risk: Preserving the Principles maintains a federal supervisory signal that large institutions should identify and manage climate-related exposures that can affect communities and counterparties.
- OCC examiners and supervisory staff favoring explicit expectations: Examiners who relied on the Principles retain a formal supervisory framework to assess large institutions’ climate-risk management during examinations.
- State and international regulators seeking consistency: Regulators that coordinate with the OCC or compare standards across jurisdictions benefit from continuity in the OCC’s stated supervisory expectations.
Who Bears the Cost
- Office of the Comptroller of the Currency (OCC): The agency loses discretion to remove the Principles and faces constrained options if it wants to change supervisory posture; it may need to expend resources to revise guidance in a materially different form.
- Large national banks and federal savings associations: These institutions may face continued expectations for governance, scenario analysis, and risk-management practices tied to the original Principles, which can entail compliance and reporting costs.
- Bank compliance and risk teams: Preserving the Principles maintains requirements for programmatic work on climate risk—models, stress testing inputs, and documentation—that can be costly and operationally burdensome.
- Agencies seeking flexibility to change supervisory approach: Other federal banking regulators that prefer looser or different supervisory expectations may confront coordination and policy friction if the OCC’s stance remains intact.
Key Issues
The Core Tension
The central dilemma is between preserving a stable, explicit supervisory framework for managing climate-related financial risk and protecting an agency’s authority to alter its supervisory priorities; SJR113 favors stability and Congressional oversight at the cost of constraining the OCC’s discretion to update or rescind nonbinding supervisory guidance.
Two implementation questions will determine how consequential SJR113 actually is. First, the legal effect of nullifying a rescission of supervisory "Principles" is not identical to reinstating a binding regulation: guidance can be implemented through examination practice rather than a codified rule, and the numerical impact depends on how examiners and markets treat that guidance going forward.
Second, the CRA’s prohibition on issuing a "substantially similar" rule is notoriously fuzzy. The OCC could try to achieve similar outcomes by crafting a different form of guidance, using supervisory letters, examination manuals, or rulemaking with different procedural steps, which would test the limits of the CRA bar.
SJR113 also raises administrative and coordination trade-offs. Preserving the Principles maintains a single federal supervisory posture on climate risks from one of the primary bank supervisors, which promotes consistency for large banks operating across states.
At the same time, it reduces the OCC’s latitude to update or abandon supervisory expectations in response to new information or shifts in policy. Finally, because the resolution addresses only one agency action, it leaves open how other regulators (the Federal Reserve, FDIC, state regulators) will align or diverge, producing potential regulatory fragmentation despite the narrow legal fix.
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