ARTICLE
23 February 2022

Treasury's Federal Insurance Office Takes Steps To Address Financial Risks From Climate Change

CW
Cadwalader, Wickersham & Taft LLP

Contributor

Cadwalader, established in 1792, serves a diverse client base, including many of the world's leading financial institutions, funds and corporations. With offices in the United States and Europe, Cadwalader offers legal representation in antitrust, banking, corporate finance, corporate governance, executive compensation, financial restructuring, intellectual property, litigation, mergers and acquisitions, private equity, private wealth, real estate, regulation, securitization, structured finance, tax and white collar defense.
FIO said it will issue a climate report on insurance supervision and regulation by the end of the year.
United States Insurance

Treasury's Federal Insurance Office ("FIO") joined the Network of Central Banks and Supervisors for Greening the Financial System ("NGFS"). FIO said it will issue a climate report on insurance supervision and regulation by the end of the year.

FIO plans to work with NGFS to support three priorities highlighted in FIO's Request for Information on the Insurance Sector and Climate-Related Financial Risks (issued in August 2021). As previously covered, those priorities are:

  • evaluating deficiencies in insurer regulation and supervision and their effect on the stability of the U.S. financial system;
  • determining the possibility of "major disruptions" with respect to the private insurance coverage of markets that are especially susceptible to the effects of climate change; and
  • improving FIO's and the insurance sector's efforts to satisfy climate-related objectives.

Further, FIO signaled that it will release by year end a report on "climate-related issues or gaps in the supervision and regulation of insurers, including their potential impacts on U.S. financial stability." FIO noted that the report will contain "an analysis of climate-related disclosures for the insurance sector." The forthcoming report also "may include initial analyses of selected at-risk insurance markets."

In addition, FIO's Federal Advisory Committee on Insurance (or "FACI") created a Climate-Related Financial Risk Subcommittee.

Commentary

FIO's actions suggest a furtherance of a "whole-of-government" approach to addressing climate change financial risk. FIO's approach should appeal to those who want to take a national approach to climate change regulation, even though the insurance industry is traditionally regulated at the state level.

Primary Sources

  1. Treasury's Federal Insurance Office Continues Efforts on Climate-Related Financial Risks in the Insurance Sector, Joins the NGFS

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