On March 25, 2021, the New York Department of Financial Services (NYDFS) issued for public comment “Proposed Guidance for New York Domestic Insurers on Managing the Financial Risks of Climate Change” (Guidance). Comments must be submitted by 11:59 p.m. EDT on Wednesday, June 23, 2021, and must be made using a comment template and sent to Insurance_Climate_Guidance@dfs.ny.gov.
The Guidance states that it is intended to support New York domestic insurers in managing the financial risks from climate change (climate risks). It expands on NYDFS Circular Letter No. 15 in requiring each insurer to take a proportionate approach to managing climate risks that reflects its exposure to those risks and the nature, scale and complexity of its business. While the circular letter was more conceptual, the Guidance is intended to provide a more detailed description of NYDFS expectations.