Back in March 2009, when the NAIC voted unanimously to adopt the Insurer Climate Risk Disclosure Survey, a key question was how many states – and which states – would actually administer the survey. The question lingered for a full year, at which point the NAIC membership, in a classic case of buyer’s remorse, decided to scrap the original survey and substitute a less onerous version that afforded states the discretion to make insurer participation voluntary (in contrast to the original version) and keep insurer responses confidential (also in contrast to the original version). But still the question remained: What would individual state insurance departments actually do in regard to the survey?
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