Feb. 19, 2026

OPEN LETTER TO OSFI and Bank of Canada on the US Rescission of the EPA CO₂ Endangerment Finding and Implications for Canada

OSFI – ATTN: Superintendent Peter Routledge

Bank of Canada  – ATTN: Governor Tiff Macklem

See the PDF version for the cc list and footnotes.

Dear Superintendent Routledge and Governor Macklem,

RE: US Rescission of the CO₂ Endangerment Finding and Implications for Canada

We recently issued an open letter to OSFI questioning the value of the banking sector pursuing climate action: Should Banks Push Climate Action and Emissions Reduction when the Canadian Economy is on Life Support?  Bill S-238, Climate Aligned Finance Act will kill it.[1]

The day after, OSFI published the fireside chat with Superintendent Routledge from the CatIQ* conference (*on catastrophic insurance issues and climate).[2] It is deeply concerning that there was no mention by Superintendent Routledge of the fact that the climate damage function used by the Network for Greening the Financial System, from the paper known as Kotz et al (2024) had been retracted by Nature journal; it seems likely that this damage function was used by Canada’s climate risk reporting banks and insurers that Superintendent Routledge refers to in his chat.  This is misleading to such an influential audience, to keep them in the dark about the likely over-exaggeration of climate and transition risk by the banking sector. Since OSFI continues to also

promote the use of the implausible climate scenario known as Representative Concentration Pathways (RCP 8.5)[1] we do not think the climate risk reports reflect any realistic assessment of future climate or transition risks.

Just prior to the publication of our open letter and Superintendent Routledge’s fireside chat summary, Royal Bank of Canada (RBC) had released their Climate Action Report 2026 on January 15, 2026.  One of our people sat in on the webinar launch of the report.  It is deeply concerning that RBC indicated that they are using their leverage as a large commercial office lessee to coerce their landlords into writing into their leases that the building owner will retrofit the building to Net Zero 2040 standards.

It is our understanding of The Bank Act[2] that banks are not permitted to coerce parties into anything, Section 627.04. 

Likewise, according to Section 627.03, no bank shall provide false or misleading information to customers.  Canada contributes 1.5% of global emissions; retrofitting buildings will cost a fortune and drive-up prices for all customers and will have immeasurable effects on climate change; indeed, the embodied emissions in the task will likely increase emissions.  Thus, RBC customers (and other unwitting building tenants) will be forced to pick up the tab for RBC climate ideology, with no clear benefit to the customer, the company and its shareholders, nor to Canada as a whole. 

Again, RBC’s policies are being driven by the implausible RCP 8.5 and the flawed, conflicted, and retracted Kotz et al (2024) as are those of the Bank of Canada and OSFI itself.  How is this not a violation of The Bank Act Section 627.03?

In Governor Macklem’s Feb. 05, 2026, address to the Empire Club, Toronto, it was refreshing not to find the words “climate change” anywhere in the text.  However, nowhere in the remarks was the energy sector referred to.  Governor Macklem’s forecast is, as pundits have put it on X “things will get worse and then you will die.”[3]

It seems very strange that the Bank of Canada would not see Canada’s oil, gas, coal and mining sectors as cause for optimism with global demand surging for all of these.  Is Bank of Canada anticipating the adoption of Bill S-238 and the extinguishment of the very energy and mining sectors that could almost immediately turn our economy around, if unleashed from crushing, pancaked climate policies?