Bill S-238, Climate Aligned Finance Act, will kill it.
Feb. 05, 2026
Image licensed from Adobe Stock
To: Office of the Superintendent of Financial Institutions (OSFI)
See PDF version for CC list and the footnotes.
Dear Superintendent Routledge,
We last corresponded with you on Dec. 5, 2025,[1] and we requested a reply, preferably a public statement on the retraction of the Kotz et al (2024) economic paper, upon which banks had set their climate damage function. Other than an acknowledgment of receipt, we have not received a response from you.
Despite the fact that we communicated to OSFI, in an Open Letter of Sept. 12, 2025,[2] that the Climate Risk reports that you had received from various banks and financial institutions in Canada were likely flawed due to the errors in Kotz et al (2024) and that there were concerning Conflicts of Interests surrounding this paper, it seems you took no notice of this.
In the transcript of the Nov. 9, 2025, session of CSSB and UN PRI’s “Sustainability Disclosure in Canada: Overcoming the Headwinds”, you had an opportunity to make the other panelists aware that climate risk has been wildly over-estimated by the banking sector, due to the reliance on the flawed Kotz et al climate damage function, and the misuse of the Representative Concentration Pathways scenario known as RCP 8.5, misnamed as the “business-as-usual” case, when it is implausible, if not impossible. However, based on the transcripts, you did not do that.
Fellow panelist, Grant Vingoe, of the Ontario Securities Commission stated, “We have existing standards and guidance on making accurate climate and sustainability disclosures, and we’re examining for them. What’s lost is potentially a uniform baseline, but what’s not lost is our commitment to avoiding misleading disclosure and our ambition to encourage more forthright forward-looking disclosure.” (bold added)
In the wrap up, you said, “Because we deal on the climate issue and the international for all the time, and I’ll quote our prime minister, or maybe I’ll steal a quote from him: We take note of what our international peers are doing. We don’t take direction. We’re going to do what’s right for Canada and Canada’s financial system.”
Would it not be right for Canada and Canada’s financial system that you issue a ‘recall’ of sorts, as the auto industry does when there is a potentially harmful or fatally flawed component? In terms of the many Senate and parliamentary committees you’ve addressed and banking directives that you have issued related to climate risk, it is incumbent upon you to clearly and publicly retract the climate emergency aspect of your comments and clarify that the banking sector’s reliance on Kotz et al (2024) and RCP 8.5 have fatally skewed climate and energy policies in Canada in particular, and in the world, in general.
A clear example of this is also found in the transcript. Lindsay Walton of the UNPRI stated, “And I think everybody has seen this report—the International Energy Agency report in June. We all quote it that this year investment in clean technologies was 2.2 trillion. It is set to double that of investment of fossil fuels 1.1 trillion. So, I would like to hear from each of our panelists on this: At this crucial time, how is your organization helping Canada remain competitive to benefit from the global transition to a low-carbon economy?”
The diversion of UNPRI investment dollars from conventional oil and gas to ‘low-carbon’ investments is placing the world at risk of a shortfall in conventional supply, which will create all kinds of socio-economic problems, far worse than ‘climate change.’
The investment in clean technologies is primarily due to the government subsidies offered across a scattered smorgasbord of so-called “New Economy” ideas, which includes Electric Vehicles, for example. Recall that some $50 billion in Canadian government investments in EV battery plants disappeared in what can only be called a stock pump-and-dump scheme; imagine if that money had been dedicated to properly equipping provincial wildfire crews with a buffet of mitigation money; millions for fuel-load clearing near communities so that a Jasper-megafire never threatens people again; millions for trained crews who are contracted all year, so that we don’t find ourselves at the height of autumn wildfire season when university student wildfire crews and their manpower disappear in September when we often need them most; millions for water bombers and choppers. Rather than seeking to mitigate wildfire insurance risk by Property and Casualty insurers doing geolocating of flood or wildfire risks, how about encouraging the Canadian federal government to advance funds to actually mitigate flood and wildfire risk and damage?
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