Climate Change Joint Task Force Comment Letter on NAIC Climate Risk Disclosures Survey Exposure Draft (January 10, 2022)

Comment letter submitted to NAIC’s Climate and Resiliency (EX) Task Force. The comment letter from the Academy’s Climate Change Joint Task Force addresses an exposed proposal by the NAIC for a new climate disclosure, based on the Financial Stability Board’s Task Force on Climate-related Financial Disclosures (TCFD) guideline and includes a series of observations and three specific suggestions. The comments are based on research conducted by the Academy’s Climate-related Financial Disclosures Work Group.