Federal Insurance Office: 

Update on Climate-Related Wor

Federal Advisory Committee 

Dece
FIO’s Climate-Related Priorities

FIO’s 2022 Priorities

1

Supervision and Reclimate-related issuesupervision and reguincluding their potentfinancial stability.

2

Quantitative Analyspotential for major disinsurance coverage iare particularly vulnechange impacts; faciresilience for disaste• Transition risk o

• Physical risk of 

3

Stakeholder EngageFIO’s engagement on issues, leverage the ability to achieve clim

Executive Order Tasking:“The Secretary of the Treasury shall direct the Federal Insurance Office• To assess climate-related issues or gaps 

in the supervision and regulation of insurers, including as part of the FSOC’s analysis of financial stability, and to

• Further assess, in consultation with the 

States, the potential for major disruptions of private insurance coverage in regions of the country particularly vulnerable to climate change impacts. “

--E.O. 14,030 (May 20, 2021)
By the Numbers

$110B

Estimated losses from 

2022 hurricane season, 

including $65B in insured 

losses; likely third most 

expensive to date.1

$53-74B

Estimated insured losses 

from Hurricane Ian.2

1. https://www.munichre.com/topics-online/en/climate-change-and-natural-disasters/natural-disasters/storms/hurricanes2022.html; 2. https://www.rms.com/newsroom/press-releases/press-detail/2022-10-07/rms-estimates-us67-billion-in-insured-losses-from-hurri3. https://www.swissre.com/institute/research/sigma-research/sigma-2022-01.html; 4. https://www.iii.org/article/background-on-wild5. https://www.nifc.gov/fire-information/statistics; 6. https://www.citizensfla.com/policies-in-force; 7. https://www.nola.com/news/bus410d-11ed-a47a-db6df367cb9b.html.

7M

Number of acres burned 

nationally to date in 2022 

wildfires.5

$20B

U.S. economic losses in 

2021 from wildfires, 

droughts, and excessive 

heat, including $8.7B in 

insured losses.4

557K

Increase in Florida 

residual market policies 

Jan. 31, 2021 to Oct. 31, 

2022.6

N

h

7

Global 

from se
FIO’s Data and Analytical Efforts

In August 2021, FIO issued a request for information with several questions on cliand FIO’s data collection and dissemination authorities. Responses highlighted and current lack of granular, nationwide data on climate-related risk in the insurance On October 18, 2022, FIO issued a proposed data collection to assess climate-relatacross the United States. FIO is seeking public input on a proposed collection of datand casualty insurers regarding current and historical underwriting data on hominsurance. This proposed collection would not include personally identifiable dahomeowners or specific businesses.The request for comment is part of a broader effort to explore the various avenues F

statutory mandate. It is also consistent with the Executive Order’s tasking for FIO to 

potential for major disruptions of private insurance coverage in regions of the coparticularly vulnerable to the impacts of climate change. That analysis could inc

assessment of availability of insurance for policyholders, as well as affordability. 

Federal Register Notice Data Template I
Proposed Scope of Data Collection (1/2)

Proposed Key Elements Proposed Scope for Public Consultation

1 Underwriting Focus Physical risk from underwriting by P&C insurers, exc2 Insurance Lines of Business

Homeowners’ multi-peril line of business (excludes f

3 Insurers

(1) Nationwide insurers writing above a premium th

million in 2021 homeowners’ insurance premium

(2) Additional insurers in order to achieve an 80% m

threshold in each of 10 states that are potentially vulnerable to climate-related disasters

4 Data Elements

Information regarding claims, premiums, and losses 

data fields reported by U.S. insurers to state insuranannual filings, as well as additional policy information statutory filings

• Flood damage typically not covered by homeowners’ m• FEMA conducting analyses on flood insurance; FIO co
Proposed Scope of Data Collection (2/2)

Proposed Key Elements Proposed Scope for Public Consultation

5 Reporting Framework Accident year reporting basis6 Reporting Period Five years of underwriting data (2017-2021)7 Geographic Granularity

ZIP Code level for all U.S. ZIP Codes applicable to in

8 Geographic Scope Nationwide9 Reinsurance Impact Direct business basis only, excluding reinsurance

FIO chose ZIP Code level data because:• State-wide information would not provide sufficient gra• Insurers price policies based on risk in a localized area• FIO has mandate to assess the availability of insuranc

affordability of such products for vulnerable communitiand low- and moderate-income populations.

• ZIP Code information is collected as part of homeowne• ZIP Codes are unique, numerical identifiers.• ZIP Code analyses have been conducted by state insu

certain circumstances.
Proposed Considerations

Determining Potentially Climate-Vulnerable States: FIO selected te

climate-vulnerable states using the FEMA National Risk Index, a publicdataset on natural hazards and social vulnerability, which combines hisprojected) risk data across 18 event types, including information on eco

– FIO aggregated the National Risk Index’s Expected Annual Loss data acro

were determined to be in scope to find potential climate-vulnerable states

– Insurance groups and stakeholders have noted the usefulness of the Natio

a resource

FIO would not use the collected data for:

– Publishing confidential, firm-specific data from individual submissions– Measuring the impact on earnings or capital of individual insurance compa
Proposed Data Template

FIO’s proposed collection of ZIP Code level data focuses primarily on data fielthrough annual statutory filings in order to minimize burden

Category IV: Policy Informa• Number of Policy In-Force E• Total $ Value of Coverage fo

Other Structures, and Perso

• Total $ Replacement Cost V• Total $ Amount of Insurance 

Category II: Claims• Number of Claims Reported• Number of Claims Closed with Loss Payment• Number of Claims Closed Without Loss 

Payment

• Cumulative Number of Claims Closed with 

Loss Payment

• Cumulative Number of Claims Outstanding• Cumulative Number of Claims ReportedCategory I: Premiums• Direct Premiums Written• Direct Premiums Earned•Amount of Direct Premiums Written Renewed 

or Retained

Category III: Losses• Total Direct Losses Paid• Total Direct Incurred Losses

Legend: Not italicized = In statutory filings | Italicized = Not in statutory filings
Engagement

The data collection is currently at the proposal stage and FIO is 

public comment and engagement on the questions posed in the general, FIO’s climate-related work will be a sequential and capexercise. The initial steps are intended to consolidate foundatioto develop more comprehensive approaches to address climatefinancial risks. 

FIO will continue to engage with FACI members, the NAIC, sta

regulators, the insurance industry, policyholder groups, academ

others to help inform the next steps of our work. 
Topics for Public Comment

FIO is requesting comment on:Underwriting focus

Insurance lines of business

Selection of insurers & states Data elements 

Focus on underwriting by P&C insurers

Additional insurance lines to consider; inclusion of NFIP and private flood policies

Premium threshold and use of National Risk Index to select potential climatevulnerable states

Elements to include or exclude; inclusion of reinsurance and additional living expenses

Reporting period 

Granularity & scope Burden Periodicity

Appropriateness of five-year period (2017-2021)

Proposal to collect ZIP Code level data with nationwide scope

Estimates of burden and ways to minimize it

Collection of data on an annual basis
Submission of Comments

FIO requests comments on its proposed data collection by December Commenters can submit:

– Electronically (recommended): Federal eRulemaking Portal at http://www– By mail: Federal Insurance Office, Attn: Elizabeth Brown, Senior Insuran

Policy Analyst, Elizabeth.Brown@treasury.gov, (202) 597-2869 or Silab M

Insurance Regulatory Policy Analyst, Silabhadra.Mohanty@treasury.gov, (Room 1410 MT, Department of the Treasury, 1500 Pennsylvania Avenue NDC 20220.