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 National Association of Mutual Insurance Companies (NAMIC) appears to have had generally negative engagement on sustainable finance policies, opposing regulatory efforts at both the federal and state levels.
NAMIC appears to oppose the need for climate-related regulation for the insurance sector despite recognizing the challenges climate change presents for the insurance industry and stating that the current ratemaking system is “unsustainable” given the trajectory of the changing climate. In a 2021 statement to the Senate Committee on Banking, Housing, and Urban Affairs, NAMIC called on Congress to implement real-economy policies to mitigate the effects of climate catastrophe, but voiced concerns about potential congressional regulation on insurers’ risk modeling and disclosures. In a 2019 paper on ESG considerations, NAMIC outlined the “problems” caused by increased government intervention and stated that any regulation of insurance in this area would be “chaotic and of no real value.” In comments to the Federal Insurance Office (FIO) in 2021, NAMIC contested the idea that climate-related regulation is needed for the insurance sector.
NAMIC appears to not support regulated corporate ESG disclosure. In its 2021 comments to the FIO NAMIC did not support mandating TCFD reporting for insurers, and in 2022 comments to the National Association of Insurance Commissioners (NAIC) NAMIC advocated for flexible, phased-in climate disclosure requirements. NAMIC’s Q4 2021 lobbying report shows engagement with the SEC on climate change disclosures, but NAMIC has not disclosed details of this engagement and has not released a public comment letter outlining its position on SEC-mandated climate disclosures.
NAMIC appears not to support the incorporation of ESG factors into investor duties. In a 2020 paper on ESG considerations, it told investors to look to the Trump Department of Labor Fiduciary Duty rule for guidance on incorporating ESG factors into investor duties. In 2021 comments to the New York Department of Financial Services (NYDFS), NAMIC voiced some support for public disclosure of insurer treatment of climate risk, but advocated that other disclosures should be available only to regulators, and cautioned about a lack of adequate data.
NAMIC has opposed regulatory action to incorporate ESG factors into risk management and prudential supervision. In March 2021, NAMIC opposed a Connecticut General Assembly bill that directed the state’s insurance commissioner to incorporate climate disclosure requirements and risk considerations into supervision of insurers, writing that it “does not support using the insurance industry as a lever to pursue a particular point of view as it relates to climate change.” In response to a California Department of Insurance hearing in 2020, NAMIC stated support for the proper modeling and pricing of climate risk, but appears to believe that insurers should take this upon themselves, emphasizing in its NYDFS comments that many insurers already incorporate climate risk into their risk frameworks and thus additional mandated stress testing could be “duplicative.” Additionally, NAMIC’s website states opposition to the NAIC Climate Risk Disclosure Survey, writing that the survey’s results may not be reliable or useful. In its 2021 comments to the FIO, NAMIC emphasized that the existing risk management framework is sufficient to address climate risks, and did not support mandating scenario analyses. In its 2022 response to the NAIC’s proposed redesign of its climate disclosure survey, NAMIC did not support requiring scenario analysis for insurers.
On its website, NAMIC has listed broad positions on only a few sustainable finance policies, and specific positions and details of engagement are password protected for members only. NAMIC has disclosed board membership but not general membership.