Comments on the Impacts of Proposed Regulatory Capital Requirements for Large Banks on Clean Energy

The staff of the Clean Energy States Alliance submitted comments to the Office of the Comptroller of the Currency, Board of Governors of the Federal Reserve System, and FDIC regarding proposed changes to the capitalization rules applicable to banks that engage in the tax equity market. We expect this change to significantly slow down or stop tax equity investments, which could directly counter state clean energy goals and implementation of the Inflation Reduction Act.