Green Century Capital Management Issues Public Comment to Treasury Dept.

TARGETED NEWS SERVICE (founded 2004) features non-partisan 'edited journalism' news briefs and information for news organizations, public policy groups and individuals; as well as 'gathered' public policy information, including news releases, reports, speeches. For more information contact MYRON STRUCK, editor, [email protected], Springfield, Virginia; 703/304-1897; https://targetednews.com

WASHINGTON, Dec. 22 -- Green Century Capital Management Inc. has issued a public comment to the U.S. Department of the Treasury. The comment was written on Dec. 16, 2022, and posted on Dec. 19, 2022.

The comment, on Docket No. TREAS-DO-2022-0021-0001, was sent to Elizabeth Brown, senior insurance regulator policy analyst of the FTC.

* * *

As a mutual fund company concerned with the multiple material risks posed by climate change, not just to the large property and casualty insurers we invest in, but to companies across our portfolios and to stakeholders in general, we're writing to support a robust data collection effort on climate-related financial risk. The information gathered by FIO's data call will help us better understand the climate-related risk that insurers may be exposed to and the extent to which vulnerable communities may be under- or un-insured as insurance companies pull back from underwriting regions prone to severe climate events.

First, we believe one item missing from the proposed data call list relates to wildfire coverage. FIO should collect data on standalone fire insurance and examine the extent to which insurance companies are responding to risk by eliminating coverage for wildfires in homeowners insurance policies.

One of our investee companies, Chubb, withdrew from underwriting parts of California three years ago citing that the risk/return ratio was no longer favorable. We would like to understand the extent to which insurers are pulling out of wildfire prone areas like California and what choices that leaves for remaining residents.

Second, we believe that FIO should encourage insurers and their state regulators to look beyond climate risk related to their individual state insurance markets and examine how insurance companies themselves enhance climate risk by underwriting and investing in high-emitting projects related to the coal, oil, and gas industries. Without plans, goals, metrics and timelines for transitioning conventional energy clients to a low-carbon economy, insurers will contribute to enhancing the effects of climate change and subsequently cannibalize their own markets or outprice existing customers or both.

State regulators can help by following the lead of the New York Department of Financial Services and encouraging insurers to manage climate-related financial risks by reducing their investments and underwriting of fossil fuels. FIO should also recommend that the Financial Stability Oversight Council and Office of Financial Research investigate the effects of insurer responses to the climate crisis on financial stability.

Again, we value FIO's data collection efforts and will look forward to your report which we feel will give investors the information they need to understand how insurers are/are not addressing climate risk, how vulnerable populations may be at risk, and how others (such as investors, regulators etc) have a role to play in lessening the financial impacts of climate change.

Sincerely,

Andrea Ranger

Shareholder Advocate

Green Century Capital Management

* * *

Original text here: https://downloads.regulations.gov/TREAS-DO-2022-0021-0008/attachment_1.pdf

TARGETED NEWS SERVICE (founded 2004) features non-partisan 'edited journalism' news briefs and information for news organizations, public policy groups and individuals; as well as 'gathered' public policy information, including news releases, reports, speeches. For more information contact MYRON STRUCK, editor, [email protected], Springfield, Virginia; 703/304-1897; https://targetednews.com