Federal Insurance Office Releases Responses to Request for Information on the Insurance Sector and Climate-Related Financial Risks

Locke Lord LLP

In a September 1 InsureReinsure Blog post, we discussed the Federal Insurance Office Request for Information on the Insurance Sector and Climate-Related Financial Risks. Responses to the request were due to the FIO on or before November 15, 2021. The FIO reports that they received 5,000 separate comments from environmental groups, insurance industry groups, insurance industry regulators, insurance companies, think tanks, and individuals.  They have posted some of the responses online.

The number of reported comments indicate a strong interest in this topic both from the climate change activist community and the insurance industry.  The comments also reveal a tension between the state by state regulation of the insurance industry and the desire of climate change activists for a more national approach to addressing the insurance industry’s role in assessing and mitigating climate change risk.

Some commenters pointed to the New York State Department of Financial Services Guidance on Managing the Financial Risks from Climate Change, released on November 15 and discussed in an earlier InsureReinsure Blog post, as a guide for future regulator expectations of the insurance industry.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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