Climate Finance Policy Engagement Analysis
Climate Lobbying Overview: The Reinsurance Association of America (RAA) appears unsupportive of regulation on the (re)insurance industry. It has engaged on select real economy policies, with unclear positions.
Top-Line Messaging on Climate-Related Finance Policy: 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.” In a 2024 climate change presentation to the Minnesota House of Representatives, RAA asserted that “now is not a good time” for policymakers to impose regulations on the sector.
Position on Regulated Corporate Climate Disclosure: In June 2022 comments on the SEC’s proposed climate disclosure rule, RAA characterized the proposal as “overly prescriptive” and suggested that Scope 3 emissions disclosure be voluntary, at least for the (re)insurance industry. In a 2023 white paper, RAA asserted that “massive, duplicative” climate reporting requirements, like the SEC’s, were adding cost pressures for insurance companies.
Position on Incorporating Climate Factors Into Risk Management/Prudential Regulation: In its 2023 white paper, RAA did not support the FIO’s recommendations for state insurance regulators to address climate risk and suggested that the FIO's proposed call for data on historical underwriting would be "costly." Howerver, in 2023 RAA opposed a Texas bill that sought to prohibit the use of climate factors in insurers’ underwriting practices.
Position on Energy, Industry, and Land Transition: According to federal lobbying reports from 2022 and 2024 RAA has engaged on specific renewable energy policy and the US Inflation Reduction Act, but details of this engagement are unclear.