January 8, 2010
Sent Via E-Mail to Pam Simpson
Mr. Eric Nordman
National Association of Insurance Commissioners (NAIC)
2301 McGee Street, Suite 800
Kansas City, MO 64108
RE: Documents related to the Insurer Climate Risk Disclosure Survey
This letter is in response to the request by the Climate Change and Global Warming (EX) Task
Force for comments on the following three items pertaining to the Insurer Climate Risk
• A prototype cover letter for use by state insurance departments that explains the purpose
of the survey;
• A prototype of the survey formatted in Zoomerang software;
• A list of insurance companies by state, based on the direct written premium of the largest
entity within the insurer group.
NAMIC has no comment on the third item, but we do wish to comment on the first two. In
addition, we’d like to share some observations about the current controversy surrounding climate
science and its relevance to the insurer climate risk disclosure process.
The Cover Letter
Missing from the cover letter is any indication that all survey responses will be made public,
with company respondents identified by name. While the survey instructions in the Zoomerang
survey prototype clearly state that “survey responses are public information” and that “the NAIC
shall coordinate a user-friendly central access point for the survey document and insurer
responses,” we think this information is important enough that it should be prominently disclosed
in the cover letter as well.
Moreover, given that according to the cover letter, the purpose of the survey is to “assist
regulators in assessing insurers’ risk assessment and management efforts relate to climate risk,”
we believe it would be helpful if the letter were to explain how public disclosure of insurer
responses will advance that purpose.
The letter’s first sentence states in part: “This letter is to inform you that [insert state,
commonwealth, territory] has dec