This week, CARI sent the following letter to Beth Dwyer, Director of the Rhode Island Department of Business Regulation and Vice Chair of the Climate Risk Steering Group of the International Association of Insurance Supervisors, calling on her to lead climate action in her industry.
Dear Director Dwyer:
We write to you today from Climate Action Rhode Island, a local organization of over 3,000 Rhode Islanders combating the climate crisis, as you prepare for the International Association of Insurance Supervisors (IAIS) annual meeting, to express our deep concern that insurance supervisors and regulators are taking insufficient action to address climate change.
In 2021, the Financial Stability Oversight Council identified climate change as an “increasing and emerging threat” to the financial system. Insurance is “unique in that it both faces climate-related financial risk itself and plays a critical role as a manager of climate-related financial risk for other financial institutions.” Insurance in the United States is also unique because it relies on a state-based system for regulation. Therefore, the responsibility for effectively integrating climate risk into insurance regulation falls to state regulators like you. As such, we urge you to exert leadership at the upcoming IAIS meeting.
Industry is failing to address climate risk
August 2023 marked 50 years since the insurance industry first warned about the increasing risks of climate change. Meanwhile, the climate crisis has become a grim reality for billions of people – unprecedented heat waves, wildfires and floods have ravaged countries around the world. This acceleration of the climate crisis is translating to more rapid and more chaotic dysfunction in the insurance market than many anticipated.
Since 2017, the insured losses from natural disasters (and mostly human-made climate disasters) averaged $110 billion per year, more than double the average amount in the previous five years. In response, reinsurance and primary insurance rates have increased rapidly, and growing parts of the United States, Australia and other countries risk becoming uninsurable.
Greenhouse gas emissions from the energy sector reached a record amount in 2022. Yet in spite of its powerful role as a global risk manager, the insurance industry is not using its influence to accelerate the transition from fossil fuels to clean energy. Instead, it is adding fuel to the fire by underwriting the continued expansion of oil and gas extraction.
While corporate fossil fuel expansion is insured, everyday homeowners and businesses are not. Treasury Secretary Janet Yellen warned of a “protection gap” across the insurance industry, estimating that only 60% of $165 billion in damages from climate disasters in 2020 were covered by insurers. In addition to inflicting major burdens on households and businesses, this “protection gap” also further raises financial stability concerns because of the possibility that more frequent catastrophic climate events could trigger losses that spread throughout the economy through defaults, delays, underpayments, and so on.
Meanwhile, actuaries are sounding the alarm about the extreme inadequacies of current risk modeling and management practices. The Financial Stability Board and the Network on the Greening of the Financial System have also acknowledged the significant limitations of climate scenario analysis as it currently stands.
Current insurance regulations are patchy
Despite the chaotic outcomes in the insurance market, there has been little in the way of a coordinated effort to get a handle on climate risk by regulators. The global regulatory environment on insurance and climate-related financial risk is patchy at best, and the U.S. is no exception. This points to the need for regulators to work together to create a level playing field.
As the U.S. Treasury Department’s Federal Insurance Office (FIO) noted in its June 2023 report on the supervision and regulation of climate-related risks in the U.S. insurance industry though, “there are nascent and important efforts to incorporate climate-related risks into state insurance regulation and supervision…efforts are fragmented across states and limited in several critical ways.”
We therefore call on the IAIS to:
- Take a precautionary approach to addressing environmental risk: Environmental risks – including both climate- and nature-related risks – are still a regulatory blindspot. Too much reliance is placed on historical data in addressing the risk, whereas by definition climate change and biodiversity loss are forward-looking, non-linear and irreversible phenomena. The IAIS must provide guidance to supervisors on how to include environmental risk into the supervisory framework, and reflect the risks in capital standards for the internationally-active insurance groups.
- Set expectations for credible transition plans: The IAIS should offer best practice guidance to ensure that insurance companies adopt transition plans with short-, medium- and long-term targets and aligned with credible 1.5°C pathways. Supervisors should review transition plans to understand an insurer’s levels of transition risk exposure. The guidance should follow the UN HLEG Standards on Net Zero Commitments by Businesses, Financial Institutions, Cities and Regions.
- Steer the industry away from exacerbating climate risk: The IAIS should offer best practice guidance for supervisors to ensure that insurers consider climate-related risk implications for their solvency position. The IAIS work on capital standards should be based on a precautionary approach to capital requirements reflecting the “one-for-one” rule (a dollar of capital held per dollar invested) for any investments in the fossil fuel sector across all asset classes.
- Don’t let contributors to the crisis get public support: The IAIS should propose rules to ensure that insurance companies that still underwrite or invest in new fossil fuel projects are excluded from managing or participating in any programs supported with public funds to insure climate risks and strengthen climate resilience.
- Rely on climate science: The IAIS must ensure supervisors mandate the use of climate science when assessing possible impacts of the climate crisis, as opposed to the flawed prevailing economic models, which by design are not able to capture the consequences and non-linear complexity of climate change, and substantially underestimate its economic cost.
Given your role as the Vice Chair of the Climate Risk Steering Group, we ask that you raise these concerns and recommendations with IAIS leadership. Thank you for your attention and consideration.
The members of Climate Action Rhode Island
In partnership with the following local & state-based organizations:
350 Conejo / San Fernando Valley (CA)
350 Seattle (WA)
350 Wisconsin (WI)
350 Yakima Climate Action (WA)
350 Juneau–Climate Action for Alaska (AK)
7 Directions of Service (NC/VA/SC)
Climate Families NYC (NY)
Climate First!, Inc. (MD)
Connecticut Climate Action Committee (CT)
Earth Ethics, Inc. (MD)
Green Education and Legal Fund (NY)
Missing Murdered Indigenous Women Coalition of NC (NC)
MN350 Action (MN)
Multicultural Real Estate Alliance for Urban Change (CA)
Regenerating Paradise (CA)
Rise Economy, formerly California Reinvestment Coalition (CA)
Rivers & Mountains GreenFaith (NY)
Sixth Street Community Center (NY)
Society of Native Nations (TX)
Texas Campaign for the Environment (TX)
The Center for Social Sustainable Systems (NM)
The CLEO Institute (FL)
And the following US-based organizations:
Climate Hawks Vote
Climate Organizing Hub
Indigenous Environmental Network
One Earth Sangha
Revolving Door Project
Union of Concerned Scientists