Ally Financial Inc – Lobbying Governance & Transparency

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Lobbying Governance

Overall Assessment	Analysis	Score
Limited	Ally Financial reports that it "employs internal lobbyists and external consultants" and maintains "a robust compliance and monitoring program to ensure both its employees and consultants abide by all appropriate conduct, reporting and disclosure requirements," and further states that "the CNGC, which is composed entirely of independent directors, oversees Ally’s public policy activities, including lobbying activities, memberships in trade associations, coalitions, and industry organizations," indicating formal oversight of its lobbying function. While Ally details engagement in climate-related industry forums such as the "RMA Climate Risk Consortium, the American Bankers Association Climate Task Force and the Bank Policy Institute Climate Working Group" to "inform ongoing policy considerations specific to a changing climate," it does not describe any policy or process to align or review how its lobbying activities support its climate change strategy, and confirms that it has "no" public commitment to conduct engagement in line with the Paris Agreement and does "not plan to have one in the next two years." We found no evidence of mechanisms for monitoring or managing the alignment of direct or indirect lobbying with its climate objectives, indicating limited transparency on how it integrates climate goals into its lobbying governance. View Sources	D

Overall Assessment

Analysis

Score

Limited

Ally Financial reports that it "employs internal lobbyists and external consultants" and maintains "a robust compliance and monitoring program to ensure both its employees and consultants abide by all appropriate conduct, reporting and disclosure requirements," and further states that "the CNGC, which is composed entirely of independent directors, oversees Ally’s public policy activities, including lobbying activities, memberships in trade associations, coalitions, and industry organizations," indicating formal oversight of its lobbying function. While Ally details engagement in climate-related industry forums such as the "RMA Climate Risk Consortium, the American Bankers Association Climate Task Force and the Bank Policy Institute Climate Working Group" to "inform ongoing policy considerations specific to a changing climate," it does not describe any policy or process to align or review how its lobbying activities support its climate change strategy, and confirms that it has "no" public commitment to conduct engagement in line with the Paris Agreement and does "not plan to have one in the next two years." We found no evidence of mechanisms for monitoring or managing the alignment of direct or indirect lobbying with its climate objectives, indicating limited transparency on how it integrates climate goals into its lobbying governance.

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Lobbying Transparency

Overall Assessment	Analysis	Score
Limited	Ally Financial Inc. offers only limited insight into its climate-policy lobbying. It acknowledges that it seeks to shape climate-related “taxonomy, frameworks and standards” through participation in the American Bankers Association, the Bank Policy Institute, and the Risk Management Association, but it does not identify any specific laws, regulations or bills it has tried to influence. The company explains that these associations serve as its primary channel of engagement, yet it gives no detail about how influence is exercised—such as meetings, letters or consultations—nor does it name the government bodies or individual officials that are approached. Finally, its disclosures stop at a general statement of intent to align with initiatives like the Paris Agreement and to inform climate-related policy; they do not spell out concrete legislative changes, numerical targets, or amendments it is advocating for. As a result, the company is only partially transparent across all three dimensions of climate-lobbying disclosure.	D