Topic: Climate Change

Connecticut Department of Insurance Proposes Guidance on Climate Change Financial Risk

Following on the heels of the New York Department of Financial Services (“NYDFS”), the National Association of Insurance Commissioners (“NAIC”) and the U.S. Security and Exchange Commission (“SEC”), the Connecticut Department of Insurance on April 22, 2022 proposed guidance for domestic insurers on managing climate change financial risk.  Like the NYDFS, the NAIC and the SEC programs, the proposed guidance is based on the framework develop by the Task Force on Climate-related Financial Disclosure (“TCFD”).

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California Department of Insurance Releases its Climate Risk & Resilience Analysis Survey

On April 18, 2022, the California Department of Insurance (“CDI”) released its Climate Risk & Resilience Analysis Survey performed by S&P Global Market Intelligence. The survey’s analysis assessed insurer investment portfolios from December 2018 to December 2019 and reviewed insurer investments in the fossil fuels and energy sectors, under the EU green taxonomy, and in green bonds. Through the report, the CDI is attempting to understand the exposure of the California insurance industry to financial risks associated with insurer investments in oil, gas, coal and electric utilities. The CDI has also started assessing insurer investments in green assets with the purpose of tracking the transition to a more sustainable economy.

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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. 

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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.

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