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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 Atlantic Ocean have been keeping up the pace—and there will be more to report in early 2021.
This brief update piece will focus first on a December 16, 2020, Sustainable Finance Roundtable from the European Insurance and Occupational Pensions Authority (EIOPA), then on upcoming comments (due on January 12, 2021) on the International Association of Insurance Supervisors’ (IAIS) “application paper” about managing climate change risks. Next, the New York Department of Financial Services (DFS) held the second in a series of climate change briefings in early December and has another session scheduled for January 15, 2021. The DFS has also published some guidance for industry in the form of FAQs and right before Christmas posted a “pre-proposed outreach” proposal for a second amendment to New York’s Enterprise Risk Management (ERM)/Own Risk and Solvency Assessment (ORSA) Regulation 203 (comments due January 8, 2021). Finally, also pre-Christmas, the industry itself, notably the Lloyd’s Market, weighed in with climate change-related goals to reduce and then phase out underwriting and investments in coal-related businesses.