The U.S. Chamber of Commerce (“the Chamber”) is pleased to respond to the International Association of Insurance Supervisors (“IAIS”) public consultation on climate risk supervisory guidance (“the consultation”). While the Chamber agrees that climate change is a source of risk that insurers should account for, we question the implication that climate change is currently a financial stability risk to the insurance sector.
The Chamber has long supported practical, flexible, predictable, and durable market-based solutions to address climate risk. Our members are driving private sector innovation across industry sectors that will be central to solving climate change.
To ensure optimal policy outcomes, the best science and observations available, identification of material risk, and a rigorous assessment of available alternatives through cost-benefit tradeoffs should be the drivers of climate-related financial services policy. Billions of dollars in private-sector research and development have led to the creation and implementation of innovations that help manage climate
risk, accelerate emissions reductions, and help communities and companies adapt and build resilience; the insurance industry has been at the leading edge in addressing the impacts of climate change for years. Insurers have undertaken voluntary actions to address climate-related financial risk, including changes in underwriting, promoting resilience and predisaster mitigation for at-risk assets, and changes in long-term investment strategy to prepare ahead of the next crises.
The Chamber is committed to addressing these challenges with market-centered solutions and welcomes the opportunity to engage in constructive collaboration towards these ends
