[Full response attached]

...We have maintained a constructive and transparent dialogue with Rainforest Action Network, BankTrack and some of the other sponsors of the annual Fossil Fuel Report Card for several years...we would like to share with you additional information not covered in the Report Card on our extensive efforts to address the climate crisis...Our Statement on Human Rights (2018) notes that the global and long-term effects of climate change present a "systemic risk" to human rights...a central pillar or our work has been a series of ambitious sustainable finance goals dating back to 2007. We achieved the most recent of these – our 10-year goal to finance and facilitate $100 billion in environmental finance – in just over 5 years...in the past year we enhanced our ESRM Policy to prohibit all project-related financial services for coal-fired power plants and thermal coal mines and instituted a phase-out of business to thermal coal mining companies globally by 2030...We were also early adopters of the Recommendations of the FSB's Taskforce on Climate-related Financial Disclosures, detailing our initial implementation efforts in our November 2018 TCFD report, Finance for a Climate-Resilient Future...