On October 13, 2022, the Illinois Department of Insurance (the “Department”) issued Company Bulletin 2022-16 (the “Bulletin”). The Bulletin is addressed to all domestic insurers and advises that the Department will now participate in the National Association of Insurance Commissioners Climate Risk Disclosure Survey (the “Survey”).
NAIC Adopts New Climate Risk Disclosure Standard for its Survey
The NAIC adopted at its April 7 meeting the recommendations of its Climate Risk & Resiliency Task Force to revise its Climate Risk Disclosure Survey. As we described in our Locke Lord QuickStudy: Insurers Hit with Two Climate Disclosure Developments on the Same Day, the revisions make the Survey consistent with the international Task Force on Climate-Related Financial Disclosures (TCFD) disclosure framework.
SEC and the NAIC Propose Significant New Climate Reporting Requirements
On March 21, the Securities and Exchange Commission and the National Association of Insurance Commissioners both proposed significant revisions to climate disclosure rules. If adopted, these rules would require affected insurers to disclose climate-related risk assessments and management at the board and C-Suite level and, in some instances, Scope 3 greenhouse gas emissions.
Federal Insurance Office Releases Responses to Request for Information on the Insurance Sector and Climate-Related Financial Risks
In a September 1 InsureReinsure Blog post, I discussed the Federal Insurance Office Request for Information on the Insurance Sector and Climate-Related Financial Risks. Responses to the request were due to the FIO on or before November 15, 2021.
Insurers in the Mix at COP 26 in Glasgow, Scotland
In addition to the discussion of the future of the energy sector at the 26th United Nations Climate Change Conference of the Parties (”COP26”) taking place in Glasgow, Scotland from October 31 – November 12, 2021, there has also been a discussion of the role of the insurance industry in addressing climate change.
The United States Hit With 18 Separate Billion-Dollar Disasters So Far in 2021, a New Record
On October 8, 2021, the National Oceanic and Atmospheric Administration (“NOAA”) announced that the number of billion-dollar plus disasters so far in 2021 had achieved a new record high of 18 as of the end of September, putting 2021 on a pace to exceed the record number of billion-dollar plus disasters set in 2020.
Federal Insurance Office Spells Out Priorities Regarding Climate-Related Financial Risks in Insurance Sector
On August 31, 2021, the Federal Insurance Office (“FIO”) issued a request for information regarding climate-related financial risk in the insurance sector. In the Request, the FIO laid out a conceptual framework for categorizing climate-related financial risk and its three pronged approach to implement portions of the President’s January 27, 2021 Executive Order on the Climate Crises and his May 20, 2021 Executive Order on Climate-Related Risk in the Financial Sector.
Connecticut Insurance Department Releases its National Climate Risk Survey
On August 16, 2021, The Connecticut Department of Insurance released its National Survey on Climate Risk in the Insurance Industry. The survey’s main objectives are for insurers to report on climate-related risks and to provide the Department with more information to evaluate climate risk.
Connecticut Passes the First Climate-Related Risk Legislation in the United States
The Connecticut General Assembly passed climate-related risk legislation on June 17, 2021 in a section of its state budget implementation bill, making this legislation the first climate-related risk legislation in the United States. SB 1202 Section 346 incorporates provisions of SB 1047, a bill introduced by the Insurance Committee and Real Estate Committee.
New York Department of Financial Services Issues Proposed Guidance for Managing the Financial Risks of Climate Change
New York Department of Financial Services (DFS) released its climate change guidance New York domestic insurers for comment on March 26, 2021. The Guidance, found here, seeks to support domestic insurers in managing the financial risks associated with climate change.