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Topic: Climate Change

Illinois to Participate in the Climate Risk Disclosure Survey

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”).

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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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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.

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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.

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