Climate change is a global crisis requiring urgent action. Exceeding a 1.5°C warming scenario presents risks to the planet, economies, investors, and ultimately to the long-term profitability of banks: projections have found that limiting global warming to 1.5° degrees could save $20 trillion globally by 2100, while exceeding 2 degrees could lead to climate damages in the hundreds of trillions.1 Estimates show that 10% of global economic value stands to be lost by 2050 under current emissions trajectories.2 Reflecting this, CIBC states that climate change poses a significant risk to its business and recognizes the financial sector is uniquely positioned to make positive change for the climate.3 Investors strongly agree with this sentiment and believe the bank can be a global leader in this respect. As indicated by CIBC, the bank’s ability to meet its net-zero target relies on disclosing and reducing financed emissions. Publishing emissions data associated with automotive, power generation, oil & gas, commercial real estate, residential mortgages, motor vehicle loans, and agriculture lending is a positive step.4 CIBC’s associated 2030 interim targets for oil & gas, power generation, and automotive reinforces the bank’s commitment to climate action. Despite this, investors are left with significant uncertainty regarding CIBC’s strategy to meet these targets and thrive in a carbon constrained economy. Investors lack key information such as definitive rubrics for sectors with targets, target setting timelines for additional sectors’ financed emissions, and a clearly outlined support and consequence path for clients ranked in Carbon Scoring Categories. While CIBC has referenced communication of interim financed emissions targets with clients, investors continue to lack clarity on how expectations and standards are conveyed, and how climate ambitions influence the lending process. Several of CIBC’s peers provide more clarity on how they are implementing transition plans. For instance, RBC has disclosed assessment frameworks adapted for sectors with interim targets.5 Australia and New Zealand Banking Group publishes client ratings movements and whether a sector is on track or not to meet the associated targets.6 Standards and guidelines exist to help financial institutions and their clients operationalize net zero commitments and can help ensure investors that CIBC has appropriate strategies in place to meet 2030 targets. From an investor vantage point, failing to set these expectations exposes CIBC to material financial risks, including but not limited to: significant counterparty risk due to stranded assets, declining credit quality, increased risk in other portfolios, and loss of goodwill. The disclosures requested in this proposal will help assure investors that CIBC has effective and accountable client transition plans in place for achieving 2030 emissions reduction goals.