Financial Institutions (FI) have always faced environmental risk exposures as a result of liability imposed upon them under the Comprehensive Environmental Response,Compensation, and Liability Act of 1980 (CERCLA, also known as Superfund) for cleanup and reimbursement costs associated with the release of hazardous substances. In spite of various defenses under CERCLA’s “safe harbor” provision for lenders, an FIs’ activities associated with bankruptcies, workouts or divestment of assets may not shield them from liability.