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For U.S. property/casualty insurance carriers, the landmark proposal by the U.S. Securities and Exchange Commission (SEC) on the disclosure of climate-related risks and greenhouse gas emissions (GHG) is a complicated matter.

Executive Summary

A landmark proposal by the U.S. Securities and Exchange Commission on the disclosure of climate-related risks and greenhouse gas emissions gives some leeway for compliance, but the time is now to prepare for complex and demanding disclosures, experts told Insurance Journalist Russ Banham, noting that disclosure of "Scope 3" emissions will be a particularly problematic exercise for P/C insurers and reinsurers.

For several years, many insurers have voluntarily provided climate risk disclosures and pledged to reduce their investments in and underwriting of companies that produce high volumes of greenhouse gas emissions. Assuming the SEC proposal is adopted and implemented as proposed, carriers will need to show exactly when and how this will be accomplished.

Released in March, the nearly 500-page proposal, formally called “The Enhancement and Standardization of Climate-Related Disclosures for Investors,” is based on the global standard set by the Financial Stability Board Task Force on Climate-Related Financial Disclosures. Expectations are for aspects of it to change, albeit not markedly, following the receipt of public comments through June 17.Legal challenges also are anticipated, based for the most part on arguments that the SEC is overstepping its bounds. In a sharply worded dissenting opinion, SEC Commissioner Hester M. Peirce stated that the SEC is not an acronym for the “Securities and Environmental Commission.”

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