Regions Financial Corp – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Moderate	Regions Financial Corp has a process for aligning its climate policy engagement with its broader climate strategy, as evidenced by its stated approach to intentional selection of participation opportunities "through regular communication among internal stakeholders" and its practice to "escalate the opportunity to the Board of Directors, in order to better enable its oversight of our climate engagement strategy." This approach extends to indirect lobbying activities through trade associations, as “similar cross-functional groups are also leveraged when determining the appropriate opportunities to participate in trade associations' environmental roundtables, working groups, and task forces.” The company discloses that its Government Affairs team "is engaged with policymakers, peer banks and industry trade associations to ensure potential policy changes are vetted and tailored to the needs of the industry and our clients," indicating a formal governance structure for policy engagement. However, the company does not disclose a specific audit or review of its climate-related lobbying or any third-party evaluation of climate lobbying alignment, and the governance for direct lobbying alignment with its climate positions is not clearly defined in its public disclosures. View Sources	C

Overall Assessment

Analysis

Score

Moderate

Regions Financial Corp has a process for aligning its climate policy engagement with its broader climate strategy, as evidenced by its stated approach to intentional selection of participation opportunities "through regular communication among internal stakeholders" and its practice to "escalate the opportunity to the Board of Directors, in order to better enable its oversight of our climate engagement strategy." This approach extends to indirect lobbying activities through trade associations, as “similar cross-functional groups are also leveraged when determining the appropriate opportunities to participate in trade associations' environmental roundtables, working groups, and task forces.” The company discloses that its Government Affairs team "is engaged with policymakers, peer banks and industry trade associations to ensure potential policy changes are vetted and tailored to the needs of the industry and our clients," indicating a formal governance structure for policy engagement. However, the company does not disclose a specific audit or review of its climate-related lobbying or any third-party evaluation of climate lobbying alignment, and the governance for direct lobbying alignment with its climate positions is not clearly defined in its public disclosures.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Limited	Regions Financial Corp offers only a basic picture of its climate-policy lobbying. It acknowledges activity through “trade association engagement on legislation and regulatory policy” and notes that “Regions participated in the process of preparing the American Bankers Association’s June 2022 comment letter to the U.S. Securities and Exchange Commission” on the SEC’s proposed climate-related disclosure rule, but it names no other specific laws or regulations. The only clearly described mechanism is this participation in a trade-association comment letter; other references to “discussions with policymakers representing constituencies across our footprint” or work by “our Government Affairs team” are not accompanied by details of meetings, letters or the individual public-sector bodies involved. Likewise, the bank does not spell out what policy change it supported or opposed, saying only that engagement is intended “to ensure potential policy changes are vetted and tailored to the needs of the industry and our clients,” which does not reveal a concrete legislative outcome. As a result, the disclosure provides limited transparency on the policies addressed, the methods used, and the outcomes sought in its climate-related lobbying.	D