The National Association of Insurance Commissioners adopted the “Climate Risk Disclosure Survey” in 2010 that has since been administered annually on a mandatory and public basis by a number of states in coordination with the California Insurance Department. The survey consists of eight questions regarding such matters as whether an insurer has climate change policies with respect to risk management and investment management; what current or anticipated risk climate change poses to an insurer; and what steps an insurer has taken to engage key constituencies regarding climate change. The advocacy organization Ceres was heavily involved in the development of the survey’s content and has issued annual reports and scorecards evaluating insurers’ responses to the survey.
NAMIC opposed the adoption of the survey based on skepticism about the propriety and utility of the NAIC’s climate disclosure survey as it was developed and when it was adopted. NAMIC has also voiced skepticism about the evaluations issued based on the survey. NAMIC agrees that climate change could well have insurance implications, but NAMIC does not support using the insurance industry as a lever to pursue a particular point of view as it relates to climate change.