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Anne Obersteadt
Senior Researcher, CIPR

NAIC Center for Insurance Policy and Research (CIPR)

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Climate Risk Disclosure

Last Updated 1/10/2019

Issue: Disclosure of climate risk is important because of the potential impact climate change can have on insurer solvency and the availability and affordability of insurance across all major categories. Recognizing the need for insurers to account for any potential effect these risks might have on the availability and affordability of insurance, some state insurance regulators administer a climate risk disclosure tool. Disclosures allow regulators a window into how insurers are incorporating these changing dynamics into their risk management schemes, corporate strategy, and investment plans. Disclosures also benefit insurers, providing them with a benchmark from which to assess their own climate change strategies. Doing so strengthens their ability to identify how climate change impacts their business. Furthermore, disclosure allows policymakers to gain an insight into needed public policy changes.

Overview: The NAIC adopted the Insurer Climate Risk Disclosure Survey (survey) in 2010. Development of the survey was in response to The Potential Impact of Climate Change on Insurance Regulation white paper, released by the NAIC in 2008. It is comprised of eight questions that assess insurer strategy and preparedness in the areas of investment, mitigation, financial solvency (risk management), emissions/carbon footprint and engaging consumers. The results provide trends, vulnerabilities and best practices related to insurers' response to climate change. The survey was modeled after the CDP (formerly named the Carbon Disclosure Project) voluntary questionnaire and, as such, cross references its questions.

Disclosure Survey Status: The survey is currently administered on a mandatory and public basis through a multi-state effort led by California. The survey has been administered online and reported to a database created by the California Insurance Department since the 2012 reporting year. The premium threshold is $100 million in direct written premium. For reference, a copy of the climate risk survey questions, guidelines and climate change resources is available.

California Department of Insurance serves as the central location for insurers, regulators and members of the public to access survey information from the multi-state initiative. The California Insurance Department developed four simple Web applications as part of their online survey tool to administer the survey. The survey results can be queried by company, line of business, question, yes/no response or customizable report through an interactive database. Individual insurer responses can also be viewed, with surveys being found by company name, group name or NAIC number. Regulator–only reports include insurer contact information, real-time survey results, quick identification of companies that have or have not filed, and automatic result analysis. The survey results can be found on the California Department of Insurance Climate Risk Disclosure Survey webpage.