Florida Office of Insurance Regulation Encourages Florida Domestic Insurers to Complete NAIC Climate Risk Disclosure Survey by July 30, 2010

 

Based upon adoption of the Climate Risk Disclosure Survey (“Survey”) by the National Association of Insurance Commissioners (“NAIC”) earlier this year, the Florida Office of Insurance Regulation has notified certain Florida domestic insurers that, although participation in the Survey is voluntary, it must be completed by July 30, 2010. 

The NAIC has set up a Web site to access and complete the Survey:

https://www.surveymonkey.com/s/ClimateRiskDisclosureSurveyWeblink

(Please be advised that this Survey tool can only be used on one user’s computer.  In order for the Survey responses to be saved, users need to have cookies and third-party cookies enabled and saved on their computers.)

To view additional information about the NAIC’s Climate Change and Global Warming and related documents, click here.

 

Additional instructions:

• Responses written in narrative style are acceptable.  In situations where an insurer’s response to other disclosure mechanisms (such as the Carbon Disclosure Project or Global Reporting Initiative) explicitly addresses the subject matter of a question in this Survey, the insurer may reference and attach its most recent response to that external mechanism in lieu of providing a duplicative response.

• Insurers are required to answer all questions in good faith and with meaningful responses. However, there is no requirement to provide information that is immaterial to an assessment of financial soundness (insurers may choose to disclose such information voluntarily, with no implication that such information is in fact material).

 

Insurers are not required to:

• Provide quantitative information;

• Provide information that they, in good faith, believe is commercially sensitive or proprietary;

• Provide forward-looking information. If an insurer chooses to provide forward-looking information, the insurer may disclaim any responsibility for the accuracy of such forward-looking information. Provided the insurer supplies such information in good faith, it may condition its response with a waiver of any claim under any theory of law based on the inaccuracy of such information.

 

To view sample Survey responses, click on the following hyperlinks:

• AEGON
• AIG
• Hartford Financial Services
• Health Insurer Samples
• Prudential

 

To view a list of insurer groups with direct written premium of over $300 million, click here.

Survey responses are confidential.  Once the survey responses are collected, the participating states will subsequently coordinate with the NAIC to develop a public aggregate report.

The Survey goal is to provide regulators with substantive information about the risks posed by climate change to insurers and the actions insurers are taking in response to their understanding of climate change risks.  Disclosure of climate change risks is deemed important by the NAIC because of the potential impact of climate change on insurer solvency, insurance availability and affordability across all major categories such as property and casualty and life and health.

The Survey contains a set of questions to help regulators assess insurers’ risk assessment and management efforts and follow up with questions as necessary, subject to applicable examination and confidentiality provisions.  The proposed disclosure builds upon existing climate risk disclosure mechanisms, but has an increased focus on issues related to insurer solvency and insurance availability and affordability.

 

 

Should you have any questions or comments, please contact Colodny Fass.