In a letter to the Treasury’s Federal Insurance Office, the National Association of Insurance Commissioners expressed “deep concern” over a proposal to collect data on climate-related risks from property and casualty insurers, and its disappointment that insurance commissioners are not involved in the effort so far.
“The unilateral process Treasury has employed to date represents a missed opportunity to work with regulators on an issue we have both identified as a priority,” the letter from NAIC leaders said. “The FIO has shown no sincere effort to engage with state regulators and has expressed their intent to refrain from a concerted effort to identify and collect accurate and actionable data.”
The NAIC said their Climate and Resilience Task Force was established more than a decade ago and deals with climate-related risks and resilience.
The FIO said in a Federal Register notice in October that it was seeking public comment on its proposal to collect current and historical insurance data on homeowners’ insurance, at a detailed zip code level.
“It is unclear how the FIO will use the data they intend to collect, and it is likely that any analysis will be misinterpreted and produce misleading results in identifying climate risks,” NAIC said. “Treasury is requesting market data from property insurance at a granular level, but it is unclear how that data will be combined with other information to illustrate specific climate risks.”
Industry associations, the American Property Casualty Insurance Association (APCIA), the National Association of Mutual Insurance Companies (NAMIC) and the Insurance Information Institute (Triple-I) have already rejected the FIO’s proposal.
The NAIC said the time the FIO spends seeking industry feedback on a hypothetical proposal “could have been better spent working with regulators to produce a data call best suited to the task.”
“The FIO must use publicly available data and work with state regulators to better inform a data collection effort to meet its ill-defined goal,” NAIC added.
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