Comment Text:
The RWCS (Real World Climate Scenarios) initiative seeks to accelerate improved climate scenario work. If challenges some fundamental aspects of the NGFS framing of the issue. Mike Clark, Founder Director of Ario Advisory, is a co-convenor of RWCS. We hope the attached RWCS Note may be of interest to CFTC.
Ario Advisory, a responsible investment advisory firm, would be pleased to engage further if that would assist in progressing CFTC's important work on this issue. There may be other areas where UK (and wider European) financial market, regulatory and policy practice could usefully inform US climate regulatory efforts.
