DEPARTMENT OF THE TREASURY FEDERAL 

INSURANCE OFFICE (FIO)

FEDERAL ADVISORY COMMITTEE ON INSURANCE (FACI)

MINUTES – February 17, 2022

The Federal Advisory Committee on Insurance (FACI) convened at 12:45 pm on 17 February 2021 via 

teleconference, with Dan Glaser, Chair, presiding.

In accordance with the Federal Advisory Committee Act, the meeting was open to the public.

Committee Members Present

DAN GLASER, Chief Executive Officer, Marsh McLennan, Committee Chair

AMY BACH, Executive Director, United Policyholders

BIRNY BIRNBAUM, Executive Director, Center for Economic Justice

QUINCY BRANCH, Chief Executive Officer, Branch Benefits Consultants

BETH DWYER, Superintendent of Banking and Insurance, Rhode Island Insurance Division

ROB FALZON, Vice Chair, Prudential

LUCY FATO, Executive Vice President & General Counsel, AIG

DOUG HELLER, Insurance Expert, Consumer Federation of America

PETER KOCHENBURGER, Associate Clinical Professor of Law, University of Connecticut School of Law

DANIEL SEROTA, proxy for Eric Andersen

JULIE SPORE, Chief Risk Officer, Transamerica 

ANDREW STOLFI, Administrator, Oregon Division of Financial Regulation

BETSY WARD, Chief Financial Officer & Chief Actuary, MassMutual

Department of Treasury Staff Present

GRAHAM STEELE, Assistant Secretary for Financial Institutions

STEVEN SEITZ, Director, Federal Insurance Office (FIO)

JIGAR GANDHI, Senior Insurance Regulatory Policy Analyst, FIO

Welcome and Opening Remarks

Chairman Glaser opened the meeting by mentioning the passing of Representative George Keister, who was a 

devoted public servant who provided invaluable expertise to FACI. Additionally, Chairman Glaser announced

that two members have exited the FACI - Greg Crabb of Amerisure and Bill Wheeler of Athene. Mr. Crabb’s 

and Mr. Wheeler’s terms expired at the end of last year. Chairman Glaser thanked Mr. Crabb and Mr. Wheeler

for their many contributions and wished each of them well. 

Chairman Glaser stated that first, the FACI will hear a FIO update from Director Steven Seitz, followed by an 

update on Treasury's climate activities by Assistant Treasury for Financial Institutions Policy Graham Steele. 

Finally, FACI will hear an update from the Availability Subcommittee followed by any new business. 

Chairman Glaser then asked Director Seitz for an update from FIO. 

Director Seitz thanked the FACI members for their attendance and added that FIO appreciates the time and 

effort that the members dedicate to the various FACI subcommittees. Director Seitz added that FIO continues 

to examine and consider the FACI advice and recommendations and looks forward to its continued valuable 

engagement. 
Director Seitz then stated that he wanted to echo Chairman Glaser’s remarks regarding Representative Keiser, 

Greg Crabb and Bill Wheeler. Director Seitz added that Representative Keiser was a devoted public servant 

with a long tenure in the North Dakota legislature, at the National Council of Insurance Legislators, and was a 

FACI member over the last several years. Representative Keiser provided significant insurance expertise as the 

co-chair of the Availability Subcommittee. Director Seitz then recognized Greg Crabb with Amerisure and Bill 

Wheeler of Athene for their contributions to FACI. 

Director Seitz then provided an update on some of FIO's recent activities on auto insurance, which remains a 

priority for the Federal Insurance Office. Director Seitz stated that FIO is moving forward on its data analysis

and appreciates the continued engagement of the Availability Subcommittee. Director Seitz then stated that FIO 

remains focused on implementation of the covered agreements with the EU and the United Kingdom in the 

United States. FIO continues to closely monitor the state progress in revising the credit for reinsurance 

measures and is evaluating those state measures for potential inconsistency with the covered agreements. FIO 

also has been monitoring developments at the U.S. states and the NAIC with respect to the group capital 

calculation and state adoption. 

Director Seitz then turned his attention to cyber and ransomware, international activities, and climate-related 

financial risk. Ransomware is not only a whole of government concern but also of concern for the insurance 

industry. The insurance industry has an important role to play in encouraging improvement to cyber hygiene 

and resiliency and in providing risk transfer opportunities through cyber insurance. To obtain additional data 

regarding the insurance treatment of cyber risk and particularly how those products interact with the Terrorism 

Risk Insurance Program, FIO published proposed revisions to our annual TRIP data call last November. These 

changes will assist FIO with considering the role of terrorism risk insurance in connection with cyber-attacks by 

providing FIO with:

1. Expanded information on the cyber insurance market generally to inform the extent to which cyber 

insurance is within the scope of TRIP,

2. Information on companies by their size of policy orders that are obtaining cyber insurance, and, 

3. Specific information on ransomware coverage and losses under cyber insurance policies. 

The proposed changes will result in more detailed cyber insurance data collection for calendar year 2021 with 

aggregated results reported in June of this year. FIO continues to anticipate that the data call will be issued in 

either late March or early April. 

Director Seitz then turned to international activities to highlight developments at the International Association 

of Insurance Supervisors with respect to the Insurance Capital Standard (ICS). The IAIS continues to monitor 

the performance of the ICS as it advances into the third year of the monitoring period. Incorporating 

supervisory feedback is one of the IAIS's main objectives for the monitoring period for an implementation of 

the ICS as a prescribed capital requirement in 2025. The IAIS has also been continuing its work on 

comparability, engaging members of Team USA as well as the CSFWG on issues surrounding the 

comparability criteria drafting group as they develop appropriate criteria for the comparability assessment that 

will take place in 2023. The IAIS still plans to issue a public consultation on the draft criteria in the first half of 

this year and consider that feedback as it works to finalize those criteria by 2022. FIO continues to work closely 

with the Federal Reserve Board, the NAIC, and the U.S. states on the important issues related to both the ICS 

and comparability. 

Director Seitz turned his attention to FIO's work related to climate-related financial risk. FIO continues to take

steps to implement the president's executive order on climate-related financial risk and FIO's climate-related 

priorities. At the last FACI meeting, FIO reported of the considerable interest in its request for information on 

its future work on the insurance sector and climate-related financial risk. FIO has engaged with stakeholders 

and commenters over the last several months and solicited additional feedback on our next steps. Based on this 
information, FIO will be officially launching the Climate-Related Financial Risk Subcommittee. FIO will also 

be disbanding the Protection Gap Subcommittee, since those issues will now be flowing through the ClimateRelated Financial Risk Subcommittee. Director Seitz thanked Amy Bach and Sean McGovern for their work on

the Protection Gap Subcommittee. Chairman Glaser thanked Director Seitz for his update and Director Seitz 

yielded the floor to Assistant Secretary Steele.

AS Steele thanked the FACI members and said it was a pleasure to be at the meeting. AS Steele mentioned that 

he is the Assistant Secretary for Financial Institutions at the Treasury Department and began with an overview 

of the climate agenda for his office along with FIO’s role. AS Steele mentioned that Treasury's overarching 

climate objectives are to ensure the resiliency of the financial system to climate-related risks along with 

enabling and expediting the global net zero market transition, which will position the economy for strong and 

sustainable growth consistent with a net zero emissions future. The 2022 climate agenda for Treasury domestic 

finance is focused on four areas:

1. Climate-related financial risk, 

2. Communities in climate transitions, including a just and equitable transition, 

3. Greening finance, and, 

4. Fiscal and federal finance climate responsibilities. 

AS Steele stated that his office is working with others in domestic finance, Treasury's new climate hub, and 

other divisions in Treasury to advance this agenda. AS Steele stated that the need for action on climate is clear -

the United States has experienced a dramatic increase in the frequency and severity of climate-related disasters 

with a corresponding increase in economic losses for the past 40 years. Economic growth, combined with 

changes in socioeconomic trends such as urbanization and the migration patterns to areas at higher risk of 

climate-related disasters, are increasing the financial risks associated with the effects of climate change. The 

increased frequency and severity of climate-related disasters, as well as the magnitude of associated insured 

losses, highlight the significance of these climate-related financial risks, as well as the important role that the 

insurance sector can play in responding to them. Based on its statutory authorities and in response to the 

president's climate-related executive orders, FIO has formulated three initial priorities for its work on climaterelated financial risks in the insurance sector. Those priorities are:

1. To assess climate-related issues or gaps in the supervision and regulation of insurers, including their 

potential impact on U.S. financial stability, 

2. To assess the potential for major disruptions of private insurance coverage in U.S. markets that are 

particularly vulnerable to climate change impacts and facilitate mitigation and resilience for natural 

hazards, and, 

3. To increase FIO's engagement on climate-related issues and leverage the insurance sector's ability to 

achieve climate-related goals. 

AS Steele mentioned that FIO recently published a request for information (RFI) seeking public input on these 

priorities to inform FIO's future work relating to the insurance sector and climate-related financial risk. The 

RFI received significant input from numerous stakeholders, with over 50 unique RFI responses from 5,300 

signatories that included over 95 organizations. Based on RFI input, discussion with stakeholders, and internal 

analysis, as well as the taskings to FIO in the executive order on climate-related financial risk, and the 

recommendations in the FSOC climate report, FIO has formulated its climate-related plan of action for 2022 to 

advance the three priorities previously outlined and will be a sequential and capacity building exercise as FIO 

works to address this important issue. The initial steps are intended to consolidate foundational knowledge that 

can be used in future years as part of the basis for developing more comprehensive approaches to address 

climate-related financial risks. FIO's new climate-related activities in 2022 will primarily be in four areas:

1. FIO intends to publish a climate report by year's end focusing on insurance supervision and regulation 
with an assessment of climate-related issues or gaps in the supervision and regulation of insurers, 

including their potential impacts on U.S. financial stability. In addition, the report will include an 

analysis of climate-related disclosures for insurers. The report may also include initial analyses selected 

at those insurance markets. 

2. FIO will begin quantitative analysis in 2022 in two areas of climate-related financial risk. This work will 

initially focus on analyzing the transition risk of insurers' investment portfolios and analyzing the 

physical risk of underwriting liabilities for property and casualty insurers' current climate-related 

exposures to assess impact on protection gaps in insurance availability, particularly in at-risk markets. 

FIO's initial focus in the near term will be on continuing to assess the best means for timely gathering 

relevant, reliable data needed in these analyses and then beginning the process of gathering the data. FIO 

is continuing to assess the use of its data collection and dissemination authorities with respect to insurers 

and reinsurers to help fill potential data gaps in standardized data. 

3. FIO will continue to prioritize stakeholder engagement, including input from this Advisory Committee. 

FIO aims to organize a series of stakeholder roundtable discussions in 2022 on topics related to the 

insurance sector and climate-related financial risk. 

4. In 2022, FIO will be assessing insurers' practices in underwriting and otherwise supporting climate risk 

solutions such as product innovation. FIO may also begin an in-depth analysis on an aggregate basis of 

insurers' practices related to the integration of climate-related ESG considerations into their investment 

management functions. 

AS Steele stated that FIO looks forward to continuing to engage with insurance stakeholders on these topics in 

2022 and reporting its findings in future years. 

AS Steele stated that he was pleased that FIO has formally been admitted to the Network for Greening the 

Financial System (NGFS). NGFS is a group of central banks and supervisors who voluntarily share best 

practices in order to contribute to the development of climate risk management in the financial sector and to 

mobilize finance to support the transition toward a sustainable economy. NGFS workstreams include the 

microprudential supervision workstream, which examines supervisory developments and updates the mapping 

of supervisory practices for integrating climate-related and environmental risks into microprudential supervision 

for banks and insurers. AS Steele concluded by stating that he looks forward to continuing to engage with the 

FACI.

Chairman Glaser thanked AS Steele for his informative remarks and the time that he took to be with the FACI. 

Chairman Glaser then turned to the Availability Subcommittee's 2022 priorities. At this time, Chairman Glaser 

yielded the floor to Birny Birnbaum. 

Mr. Birnbaum first thanked Assistant Secretary Steele for his presentation and the robust work planned for FIO

along with his efforts on climate-related risks. Mr. Birnbaum asked the membership if any industry members of 

FACI were interested in joining the Availability Subcommittee, since the subcommittee is down to seven 

members and none represents insurers or reinsurers. 

Mr. Birnbaum continued that the Availability Subcommittee met recently and received updates from FIO staff 

on the personal auto insurance affordability study update and other availability and affordability initiatives at 

FIO. The subcommittee then discussed priorities for its activities in 2022, with FIO staff also providing some 

suggested priorities for consideration. Mr. Birnbaum stated that the subcommittee has not made any decisions, 

but that he would share the list of priority issues discussed. In terms of priorities, Mr. Birnbaum explained that 

one area is continuing to monitor and assist FIO in updating the personal auto insurance affordability study. 

FIO is considering many issues regarding not only an update with more recent data based on the same 

methodology as the 2016 report, but additional options regarding new data sources and new analyses. For 

example, the subcommittee might identify different data sources and collection methods to ensure more timely 
analysis. FIO indicated that it was collecting 2018 data for a report to be produced later in 2022. Another 

potential subcommittee topic is continuing the work examining the impact of structural racism on insurance 

outcomes for communities of color. The subcommittee’s focus would be on issues where FIO can leverage its 

insurance expertise with other federal agencies or assist state insurance regulators. For example, the 

subcommittee might identify ways that FIO could revisit the 2016 Treasury statement regarding disparate 

impact analysis and share the experience and expertise of other federal agencies, like the Department of 

Housing and Urban Development or the Consumer Financial Protection Bureau, regarding methods of disparate 

impact analysis and data sources for protected class characteristics. This work might also include monitoring of 

Colorado Senate Bill 169 implementation. This law passed in Colorado in 2021 and requires the insurance 

commissioner to develop rules requiring insurer testing for unfair discrimination on the based on protected class 

status. Another example might be an analysis by the subcommittee of the use of criminal history information in 

producer licensing, insurance pricing, claim settlement, or antifraud to examine best practices for addressing 

structural racism in these areas. Mr. Birnbaum stated that a third potential topic area is continuing the 

examination of availability and affordability issues with flood insurance and other catastrophic events. Given 

the federal role in flood insurance both requiring the purchase in connection with most loans and as a direct 

provider of flood insurance, Mr. Birnbaum stated that FIO seems well situated to offer advice to improve the 

availability and affordability of flood insurance through structural changes in loan requirements, the federal role 

in providing flood insurance, and the federal role in promoting resilience in loss mitigation. The subcommittee’s

efforts may be shaped by some of the activities of the new climate subcommittee. The subcommittee is open to 

working on these topics if given a more refined scope. Mr. Birnbaum yielded the floor for any comments and 

thanked the FACI for the opportunity to present. 

Chairman Glaser asked if any members had comments relating to Mr. Birnbaum’s presentation and heard none. 

Chairman Glaser then asked for any new business and heard none. Chairman Glaser adjourned the meeting at 

1:08 p.m. 

I hereby certify these minutes of the February 17, 2022 Federal Advisory Committee on Insurance 

public meeting are true and correct to the best of my knowledge. 

_________________ 

Dan Glaser, Chair