Progress made by the National Association of Insurance Commissioners (NAIC) in developing either an overarching climate risk regulatory framework or discrete portions of a framework by the end of 2022 seems unlikely, according to a report by McDermott Will & Emery partner Thomas Dawson.
Earlier this month, the NAIC met to listen to reports of activity by its climate risk disclosure and pre-disaster mitigation committees amongst others, but the results were limited.
“There was scant activity to report, apart from some progress in developing proposed edits to the NAIC’s Financial Condition Examiners Handbook (which will need to be considered for adoption by other NAIC committees) and planning for meetings later this year to explore the possible use of scenario analyses by regulators and insurers, Dawson stated.
The NAIC has also announced switching its old climate disclosure survey to standards of the Task Force on Climate-Related Financial Disclosures (TCFD) by November. According to Dawson, however, “practically speaking, that is the sum total of the progress that the NAIC has made” this year.