We have expanded the list of climate policies we assess company engagement with to incorporate land-use related policy, referring to legislative or regulatory measures to enhance and protect ecosystems and land where carbon is being stored. Assessments under this category are currently underweighted in terms of their contribution to the overall company metrics. This weighting will be progressively increased over the next 6 months.
We adjusted the terminology used to describe the queries running down the left-hand side of our scoring matrix and added additional explanatory text to the info-boxes. This has no impact on the scores and methodology. It has been done following user feedback to improve clarity.
The American Property Casualty Insurance Association (APCIA) appears to have had generally negative engagement on sustainable finance policy, opposing regulatory efforts at both the federal and state levels and suggesting that concerns regarding the financial system and climate-related risk are overblown. APCIA has called for “science-based” action on climate and stated support for a lower carbon future.
APCIA has appeared not to support the need for sustainable finance regulation. In 2020 comments to the National Association of Insurance Commissioners (NAIC), APCIA stressed that climate action should occur primarily at the level of the real economy, and in 2021 comments to the Federal Insurance Office (FIO), APCIA cautioned against prescriptive regulations for insurers.
APCIA does not appear to support regulated corporate ESG disclosure. In 2020, in comments to the International Association of Insurance Supervisors and the NAIC, APCIA voiced opposition to mandatory TCFD reporting. In a 2021 letter to the SEC APCIA expressed its opposition to new requirements for climate risk reporting, and in 2022 comments to the NAIC, APCIA stated opposition to mandating disclosure of Scope 3 greenhouse gas emissions and advocated for more flexibility in proposed requirements.
APCIA does not appear to support policies to incorporate ESG factors into risk management and prudential regulation. In response to the New York Department of Financial Services’ 2021 public consultation on proposed guidance for insurers and climate risk, APCIA advocated for major exceptions to the inclusion of ESG factors in risk calculations and strongly opposed mandating public disclosures of prospective climate-related risks. In 2021, APCIA opposed a bill in the Connecticut General Assembly that directed the insurance commissioner to incorporate climate disclosure requirements and risk considerations into supervisory activities. In 2022, APCIA opposed a California bill that sought to require insurance companies to disclose investments in and underwriting of fossil fuel-related entities and authorized the insurance commissioner to prohibit or restrict these investments and underwriting. In comments to Insurance Journal, APCIA called this bill “unnecessary and potentially dangerous.”
Information about APCIA’s policy positions and its state, federal, and international political and judicial advocacy is password-restricted to APCIA members only. Board membership is similarly restricted and general membership is not listed.