American Property Casualty Insurance Association Expresses Concerns Regarding New NAIC Climate Risk Disclosure Mandate

WASHINGTON, March 23 -- The American Property Casualty Insurance Association issued the following news release on March 22, 2022:

Yesterday, the National Association of Insurance Commissioners (NAIC) Climate and Resiliency (EX) Task Force approved a new climate risk disclosure mandate. It will now be considered by the NAIC Executive and Plenary Committees at their Spring national meeting in Kansas City. While the proposal has been greatly improved, we continue to ask for modifications even as the program moves forward.

APCIA remains concerned that the new proposed survey requirements, which have a very short timeframe for implementation, will place a burden on the hundreds of insurers, particularly, small to mid-sized companies, which had previously been filing responses to the eight survey questions.

"For these companies, there simply may not be enough time or they may not have the resources to provide useful narrative responses as currently proposed, considering the internal governance process that will be needed for thorough responses," said David Snyder, vice president, international and counsel for APCIA.

APCIA advocated for the new requirement to be phased in with any new requirements beginning in reporting year 2023. This approach would allow companies time to provide better and more meaningful responses.

In addition, a more phased-in approach would allow more careful consideration of what matters are best discussed with regulators in a confidential setting and what are appropriate for public disclosure. Especially of concern are disclosures that must predict future developments or a company's future competitive strategy.

"Insurers are leaders in the effort to enhance natural catastrophe mitigation and reduce losses from natural catastrophes, said Snyder. "We believe the resources of insurers and regulators are best dedicated to that critically important effort. "