March 24, 2026

Open Letter:

Response requested on the recent Settlement by Vanguard vis a vis an ESG lawsuit, and other topics

^{Office of the Superintendent of Financial Institutions (OSFI)}

^Cc:

^{Bank of Canada}

^{Canadian Securities Administrators – CSA} 

^{Alberta Securities Commission}

^AIMCo

^{The Honorable Danielle Smith, Premier of Alberta}

^{The Honorable Scott Moe, Premier of Saskatchewan}

^{Toronto Stock Exchange}

^{CSSB  (via FRAS contact form)}

^{Business Council of Canada}

ATTN: Superintendent Peter Routledge

Dear Superintendent Routledge,

RE: Response requested on the recent Settlement by Vanguard vis a vis an ESG law suit brought by Texas AG Ken Paxton and others; Rescission of the US EPA CO₂ Endangerment Finding; Retraction of Kotz et al (2024); Abandonment of RCP8.5

Thank you for your correspondence department’s letter of acknowledgement of my recent Open Letter to you, on the rescission of the US EPA CO₂ Endangerment Finding.

Friends of Science Society requested that OSFI issue a public statement regarding the retraction of Kotz et al (2024), a consequential economic paper that falsely made catastrophic claims about future climate damage, and which was used by central banks and the Network for Greening the Financial System to set climate risk and related policies.  To what extent did the use of this wildly exaggerated model affect the climate risk assessments which you received last fall from the financial and insurance organizations that you supervise?   Canadians deserve to know.

Also, advocates of the Paris Agreement, like Catherine McKenna in her “Integrity Matters: Winning the Future” report, are claiming that the Paris Agreement has led to a reduction in emissions trajectory, when, in fact, the ‘reduction’ is simply due to the fact that the improbable scenario, known as RCP 8.5,[1] often cited as the ‘business-as-usual’ case, has been recognized as improbable.

In light of these three pivotal issues,

1. The rescission of the US EPA CO₂ Endangerment Finding
2. The retraction of Kotz et al (2024) which banks used for the climate damage function
3. The abandonment of RCP 8.5 for its improbable projections

what recommendations will you be offering to the financial institutions and funds that you supervise, in regard to assessing climate risk?  Please issue a public statement on these matters and how it will affect the banking, finance and securities sector in Canada. It seems that the more catastrophic climate projections have been rendered fictional and that no price on carbon is relevant.

Indeed, in light of the war in Iran and globally constrained energy, fertilizer, helium, and the  product stream for petro-chemical markets, all industries will be impacted with significant price hikes in the immediate and mid-term; encouraging, enabling or demanding a price on carbon by asset managers or the banking sector, to meet ESG (environment, social, governance) goals, seems ludicrous.

^{[1] RCP stands for Representative Concentration Pathway and is based on the work of van Vuuren et al 2011. As stated by the authors, the pathways were never meant for use in policy-making, only for research purposes.}