Canaries are the most familiar of “sentinel species” – animals (and plants) that can alert us to threats to human health and the environment. Those who know their mining history also know that canaries were first used in...more
7/17/2025
/ Climate Change ,
Disclosure Requirements ,
Environmental Social & Governance (ESG) ,
Financial Markets ,
Insurance Industry ,
Popular ,
Property Insurance ,
Regulatory Requirements ,
Risk Management ,
State Regulators ,
Trump Administration
On May 2, 2025, the Florida Senate voted to pass Senate Bill (SB) 1549, which would repeal the requirement for insurance producers to perform a diligent search of the admitted market before placing Florida risks with a...more
For more than a decade US insurance regulators have required certain insurers to file climate risk disclosure reports. In recent years, financial regulators in Europe have begun climate change scenario testing while still...more
The climate change landscape for insurers has changed dramatically this past month. There are multiple developments insurers should keep in mind – and not just the US Securities and Exchange Commission’s (SEC) recent adoption...more
3/18/2024
/ Climate Change ,
Corporate Governance ,
Disclosure Requirements ,
Enforcement Actions ,
Environmental Social & Governance (ESG) ,
Greenhouse Gas Emissions ,
Insurance Industry ,
NAIC ,
New Rules ,
Popular ,
Reporting Requirements ,
Securities and Exchange Commission (SEC) ,
Securities Regulation ,
State Legislatures
Given the vast number of proposals to close “the protection gap” offered by regulators, reinsurers, insurers, brokers and other industry participants in recent years, it is a wonder that it persists. But to many observers, it...more
The concept of “control” of insurers received significant attention from state insurance regulators last year and will receive even more in 2023. We wrote a brief report in April 2022 following the New York Department of...more
2/7/2023
/ Acquisitions ,
Banking Sector ,
Financial Services Industry ,
Insurance Industry ,
Insurance Regulations ,
Investment Management ,
Investors ,
NAIC ,
New York ,
NYDFS ,
Private Equity ,
Regulatory Oversight ,
Shareholder Rights
This update highlights some of the most noteworthy climate change-related federal and state regulatory, judicial and other developments of the past few months, and offers insights that may help guide insurers in their...more
12/12/2022
/ Climate Change ,
Department of Defense (DOD) ,
Department of Labor (DOL) ,
Environmental Social & Governance (ESG) ,
FDIC ,
FIO ,
Government Entities ,
Insurance Industry ,
NASA ,
Regulatory Agenda ,
Regulatory Requirements ,
Securities and Exchange Commission (SEC) ,
State and Local Government
This year started off with a surge of enthusiasm among US proponents of increased climate-related financial risk disclosure by insurers and others:
- Soon after the late-2021 Conference of the Parties (COP) 26 event in...more
In our report published on April 26, 2022, we discussed the New York Department of Financial Services’ (NYDFS) Circular Letter No. 5 in which it reminded the industry that acquiring less than 10% of an insurer’s voting...more
5/6/2022
/ Corporate Counsel ,
Corporate Governance ,
Department of Labor (DOL) ,
Disclosure Requirements ,
Documentation ,
Holding Companies ,
Insurance Industry ,
NAIC ,
New York ,
NYDFS ,
Private Equity ,
Reinsurance Agreements ,
Working Groups
If anyone believed that the US Securities and Exchange Commission’s (SEC) release of proposed climate change-related disclosure requirements last month might have been an isolated matter, of immediate importance only to the...more
On April 19, 2022, the New York Department of Financial Services (NYDFS) issued Circular Letter No. 5, reminding owners and potential purchasers of shares of insurance companies that acquiring less than 10% of the company’s...more
After a variety of promises concerning climate change-related regulatory development activity last year, forward movement has been relatively slow. The leading exception has been the New York Department of Financial Services...more
4/1/2022
/ Attestation Requirements ,
Climate Change ,
Disclosure Requirements ,
Financial Services Industry ,
Greenhouse Gas Emissions ,
Insurance Industry ,
Materiality ,
NAIC ,
NYDFS ,
Regulatory Oversight ,
Securities and Exchange Commission (SEC) ,
State Legislatures
The US Securities and Exchange Commission’s (SEC) recently proposed landmark climate-related disclosure rules draw attention to a broad scientific consensus that to avert catastrophic consequences from climate change, the...more
3/29/2022
/ Business Opportunities ,
Carbon Emissions ,
Climate Change ,
Disclosure Requirements ,
Energy Sector ,
Environmental Social & Governance (ESG) ,
Greenhouse Gas Emissions ,
Insurance Industry ,
Investors ,
Net Zero ,
Publicly-Traded Companies ,
Risk Management ,
Securities and Exchange Commission (SEC) ,
Webinars
For much of the past 10 years, the National Association of Insurance Commissioners (NAIC) and individual state insurance regulators have highlighted their awareness of the increasing number of insurers controlled by private...more
The insurance industry was front and center before, during and after the first days of the United Nations’ (UN) climate change summit, Conference of the Parties (COP26), in Glasgow, Scotland, which concluded earlier this...more
11/19/2021
/ Climate Change ,
COP ,
Environmental Justice ,
Environmental Policies ,
Financial Institutions ,
Insurance Industry ,
Mandatory Reporting Laws ,
NAIC ,
Net Zero ,
Regulatory Oversight ,
Reporting Requirements ,
Risk Factors ,
United Nations
In the few short weeks since our last report on climate change and the US insurance industry, the volume of climate change news has been extraordinarily high. The range of developments has been broad to say the very...more
In late November 2020, we published a high-level review of insurance regulatory developments relating to climate change, available here. In the six weeks since, regulators and industry participants on both sides of the...more
1/5/2021
/ Climate Change ,
Compliance ,
Corporate Governance ,
Disclosure Requirements ,
EIOPA ,
EU ,
Financial Regulatory Agencies ,
IAIS ,
Insurance Industry ,
ORSA ,
Proposed Amendments ,
Regulatory Oversight ,
Risk Management ,
Sustainable Finance ,
Underwriting
On Friday, October 2, Insurance Commissioner Ricardo Lara of the California Department of Insurance (“Department”) published a Notice addressed to and making several “requests,” detailed below, of both admitted and...more
As proposed legislation to establish a Federal Pandemic Risk Reinsurance Program remains under review by the US House of Representatives’ Financial Services Committee and Oversight and Reform Committee, a number of...more