This story was originally published by Newsweek and is reproduced here as part of the Climate Desk collaboration.

A European and an American walk into their local bank. Each has a savings account. The banks have the same antiseptic feel, their cash machines make the same robotic moves. There is one fundamental difference between the two, however — how they account for the vulnerability of their assets to climate change.

That’s a point that’s been made by a string of financial executives, regulators, and political figures over the past week of climate negotiations in Paris. That includes Mark Carney, head of the Bank of England, and Michael Bloomberg, former mayor of New York City, who have both called for a more uniform way to account for the huge, and accumulating, financial impacts of the warming planet in a way that will likely have rolling impacts across the global financial order far beyond the agreements reached here.

Depending on which side of the Atlantic you’re on, the bank, or mutual fund, or any other investment vehicle run by a publicly traded company, will look quite differently at the spectrum of those climate risks. In France, for example, finance companies must provide the Financial Market Authority, or AMF (France’s version of the SEC) with its annual contribution to, and risk from, climate change. Physically a bank may have a small carbon footprint — composed primarily of the cumulative greenhouse gas emissions of the energy used in its offices. But its funds are another matter: As of this year, the AMF requires that banks also provide a detailed accounting of the exposure of its various investment funds to not only the physical risks from climate change but the risks of fossil fuels’ declining value as the shift towards renewables accelerates and the world moves toward limits on greenhouse gases. The French also require banks to report what the companies they invest their funds in are doing to help move toward and finance a low-carbon future.

The French are the most rigorous, but some of their European counterparts are also taking the financial chaos threatened by climate change seriously. In Britain, disclosure laws require insurance companies to provide detailed rendering of their exposure to fossil fuel investments — which are increasingly being seen as highly risky by an array of authorities, from rating agencies to the Bank of England, which administers the British economy much like the Federal Reserve administers the American one. None of these factors are required to be reported to American investors by the SEC.

“If you’re traded in France,” said Bevis Longstreth, a former commissioner with the SEC during the Clinton administration, earlier this year, “you have to show your carbon footprint. If you’re traded in New York, you don’t have to list anything, you can pretend you don’t even have a shadow.”

That distinction between a shadow and a footprint is coming to be a significant focus within the financial community attending the climate talks in Paris this week. Concerns over the substantive financial risks that are accompanying the vast scale of natural disruptions wrought by climate change — $160 billion spent over the last several years to respond to extreme weather events in the U.S. alone, Secretary of State John Kerry announced in a speech Wednesday afternoon — are increasingly making their way into some of the world’s top financial institutions.

Carbon Tracker, the U.K.-based NGO made up of former traders and economists analyzing climate risk, issued a report last week identifying a cascade of risks facing the coal and oil companies: significant increases in energy efficiency and miles per gallon in vehicles, technological innovations in energy storage and transmission, the plunging cost of renewable energy — the cost of solar power has dropped 80 percent since 2000 — and the increasing likelihood that governments, including those assembled at the Paris climate talks, will impose a price on carbon.

At the Paris talks, the governor of the Bank of England, Mark Carney (Britain’s equivalent of the chair of the U.S. Federal Reserve) announced the creation of a new “Task Force on Climate-related Financial Disclosures” to assess the accuracy with which the G20’s financial markets reveal their vulnerability to climate risk. He asked the task force to assess the “stress points” in the financial system from climate risk, and appointed Bloomberg to run the effort. The two identified the tumult wrought by climate change as a potentially major destabilizing force on the global economy. Carney characterized the task force as an effort to rectify the current “market failure” to provide adequate information to investors about climate risks, and a significant step in the effort to “transition to a low carbon economy.”

Carney’s initiative has its roots in the financial crisis that whipped across the U.S. and Europe in 2011, triggered largely by the previously unrecognized risks from mortgage derivatives and the collapsing housing markets. Following the crisis, the G20 created the Financial Stability Board to identify stresses in the global economy and head them off to avoid a repetition of the catastrophic cascade that triggered the Great Recession. Carney was appointed the chair just as climate change began creeping into the consciousness of financial professionals. In June, and then again in September, he warned that climate change presents a profound challenge to economic stability; then he required British insurance companies to provide detailed data on exposure of their funds to fossil fuel investments. Now, Carney’s concern has extended to the entire financial community — every major trading exchange will be included in the broad assessment of risks ahead.

“He’s really been shaking things up,” says Sue Reid of Ceres, which has been meeting with the SEC over the past year in an effort to compel stricter climate disclosure standards for companies in the U.S. markets. “At the highest level, he’s telling the truth about the profound systemic and financial threat that carbon and climate present … Regulators don’t want to get caught asleep at the wheel like they were in 2011.”

Investors are already starting to get the news; last week an international coalition of environmental and shareholder groups led by announced that 500 institutions with combined assets of $3.4 trillion had begun the process of withdrawing their investments from fossil fuels, the latest development in the effort to stigmatize the fuels that contribute to climate change. On Tuesday, two of the world’s biggest institutional investors, the German insurance giant Allianz and the Dutch pension fund giant ABP, announced that they would be divesting their portfolios of fossil fuels, largely based on the high risks they perceive in the future performance of that sector. Last spring, France’s largest insurance company, AXA, did the same. And the members of the Portfolio Decarbonization Coalition, an umbrella group of major companies, convened by the U.N. Environment Program, have committed to divest a total of $600 billion in assets from fossil fuels.

So what does this mean for your pension or your investment funds? To get a sense of how the difference in disclosure policies on either side of the Atlantic translates into returns, I asked another banker: Zoe Knight, the managing director of Climate Change Research for HSBC Bank. Knight was also here in Paris, appearing on several panels to discuss how her bank, one of the world’s five largest, is advising investors how to think about the onrush of risks associated with fossil fuels. “It’s about risks and returns, and understanding bigger picture financial challenges triggered by climate change,” says Knight. “When an asset owner has to identify their carbon risk profile, it means you can assess the long-term viability of their investment. Climate disclosures allow you to make up your own mind.”

In other words, there appears to be a growing risk of not disclosing your climate risk.