Fannie Mae, Freddie Mac, and the Federal Home Loan Banks should take steps to better understand and mitigate climate-related risks in their portfolios without disrupting the housing finance system, ICBA told the Federal Housing Finance Agency.

Stability: Responding to an FHFA request for information, ICBA recommended data-backed analysis of potential climate risks that preserve the system’s stability and liquidity. Any potential policy changes should follow a cautious and transparent process, ICBA said.

Capital: ICBA also said any potential climate risks underscore the need to resolve Treasury’s ownership of the enterprises and expedite their recapitalization, with robust capital serving as the best way to mitigate risks.