Reinsurance Association of America

InfluenceMap Score
for Sustainable Finance
Performance Band
Organisation Score
Washington DC, United States
Official Web Site:

The Reinsurance Association of America (RAA) appears to take mixed positions on regulatory action on sustainable finance, and appears particularly cautious of regulations on climate-related insurance risk.

RAA appears to have recognized some of the risks climate change poses to the insurance industry, stating on its website’s Insurance Risks Database that if the current climate trajectory continues, the costs of insuring against some climate change-induced disasters, like wildfires, will be “more than the free market can bear.” RAA has called on legislators to incentivize investments in climate resilience projects and close the insurance protection gap, but has stated opposition to any regulation that would dictate how insurers manage their underwriting, investment, and risk. In comments to the Federal Insurance Office (FIO) in 2021, RAA contested the idea that climate-related insurance risks pose a threat to overall US financial stability, writing that insurers should continue operating as they have been without regulatory interference. RAA echoed this claim in comments to the National Association of Insurance Commissioners (NAIC) in 2022, stating that the possibility of climate-related risks impacting financial market stability is “remote.”

RAA appears to have a mixed position on regulated corporate ESG disclosure. In a 2021 letter to the SEC, RAA stated support for enhanced climate risk disclosure requirements in line with existing frameworks like the TCFD, but cautioned against overly prescriptive or inflexible requirements. RAA’s letter to the FIO makes the same arguments. In 2022 RAA urged the NAIC to reconsider its inclusion of close-ended questions in its redesigned Climate Risk Survey, advocating for decreased ambition in disclosure requirements. In a June 2021 press release, President Frank Nutter urged caution in any new climate disclosure regulations.

With regard to incorporating ESG factors into risk management, RAA has encouraged consideration of climate risk in insurers’ analyses but appears to oppose regulation to mandate this. In its 2021 “Guiding Principles to Address Climate Change,” RAA supported some regulatory action on climate risk management processes but did not support entity level climate stress tests. In response to a 2021 consultation by the New York Department of Financial Services regarding insurers and climate risk, RAA emphasized the need for insurers to consider the future threat that climate change poses to their operations, but stated that “exactly how an insurer evaluates and incorporates climate risk into its risk management process should not be prescribed.”

On its website, RAA has disclosed its positions and advocacy on some sustainable finance issues but appears to have omitted disclosure on others, lacking details of engagement on bills listed in its lobbying reports filed with the US Congress. Information is spread across website pages and some pages are restricted to members only. RAA has disclosed general membership but not full board membership.

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