IIF Response to NYDFS' Proposed Guidance on Managing the Financial Risks from Climate Change

The New York Department of Financial Services (DFS) published its Proposed Guidance for New York Domestic Insurers on Managing the Financial Risks of Climate Change (Proposed Guidance) for public comment in March 2021. The DFS requested that the IIF provide a response to the consultation. In its response the IIF noted the value in striving for alignment in approaches to climate risk, while recognizing that regulatory approaches ultimately should be tailored to the companies and markets within the purview of the regulator. The response is closely aligned with the IIF response to the IAIS Application Paper on the Supervision of Climate-related Risks in the Insurance Sector that was filed in January 2021. It also reflects key takeaways from the IIF Prudential Pathways paper also released in January 2021.