TCFD Current Practice to Best Practice for the Insurance Industry
Background and Purpose
Currently the National Association of Insurance Commissioners (NAIC) and other regulatory bodies seek climate risk disclosures from regulated entities in the form of annual survey responses. Additionally, the Taskforce on Climate-related Financial Disclosures (TCFD) created a framework meant to do much the same in a consistent format that promotes a comparison of the responding entities. Certain regulatory bodies, the NAIC for example, now allow respondents to disclose climate risks in the TCFD framework, in lieu of the regulatory bodies’ own frameworks.
The level of participation, scope and detail of TCFD responses from responding entities can cover a wide range. The quality and specific information included in survey responses and risk disclosure has differed widely. More relevant information and consistently prepared information is preferable. Straightforward surveys may be preferred to those that are complex or burdensome. Easily aggregated response frameworks are preferred for analysis. Through the designed consistency of the TCFD disclosure framework, the potential for easier comparisons exists, but the potential also exists that participants may not believe that a single framework accurately fits their particular business and exposure to climate risk.
Looking ahead to the potential value of moving to a uniform TCFD framework for climate risk disclosure, a set of Best Practices could be beneficial. Current practice could be segmented into Good Practice, Better Practice, and the gap between these and defined Best Practice can be analyzed. Along these lines, it would be insightful to study what the gaps are and their impact, and what the insurance industry should be aware of, related to financial disclosures of climate risks.
The Catastrophe & Climate Strategic Research Program Steering Committee (CCSRP) is seeking researchers to conduct a study of the qualitative and quantitative aspects of regulatory filings, and from among the ways to respond within the TCFD disclosure framework, determine which are accomplishing their goals and which rank as: Good, Better, Best Practices.
The following are examples of proposed topics that may be addressed regarding TCFD disclosure practices:
- participation amount and quality of disclosure from respondents
- the extent to which there is buy-in into the TCFD framework
- value added by the process
- for users of disclosure data (how it helps users)
- for providers of their own data (how it helps them)
- overcoming obstacles to success in achieving the filing and disclosure goals sought by the regulators/surveyors
- actual impact on climate risk
- awareness / understanding
- mitigation / reduction of impacts
- breadth of risk impacts addressed
- physical risk
- insurance risk
- liability risk
- transition risk
- investment risk
- Future use of filing and how it could change as time goes on and more is done.
- Examples of areas that can promote comparability of disclosures.
- The scenarios on which quantitative modeling and estimates are based.
Note that the above list is not meant to be exhaustive but merely examples of proposed topics that may be researched.
The scope of the filings would be those in the U.S. and Canada. TCFD filing and disclosure practices are already more established in regions outside North America, and the CCSRP seeks research to study North American bodies and practices.
To facilitate the evaluation of proposals, the following information should be submitted:
- Resumes of the researcher(s), including any graduate student(s) expected to participate, indicating how their background, education and experience bear on their qualifications to undertake the research. If more than one researcher is involved, a single individual should be designated as the lead researcher and primary contact. The person submitting the proposal must be authorized to speak on behalf of all the researchers as well as for the firm or institution on whose behalf the proposal is submitted.
- An outline of the approach to be used (e.g. literature search, model, etc.), emphasizing issues that require special consideration. Details should be given regarding the techniques to be used, collateral material to be consulted, and possible limitations of the analysis.
- A description of the expected deliverables and any supporting data, tools or other resources.
- Cost estimates for the research, including computer time, salaries, report preparation, material costs, etc. Such estimates can be in the form of hourly rates, but in such cases, time estimates should also be included. Any guarantees as to total cost should be given and will be considered in the evaluation of the proposal. While cost will be a factor in the evaluation of the proposal, it will not necessarily be the decisive factor.
- A schedule for completion of the research, identifying key dates or time frames for research completion and report submissions. The CCSRP is interested in completing this project in a timely manner. Suggestions in the proposal for ensuring timely delivery, such as fee adjustments, are encouraged.
- Other related factors that give evidence of a proposer's capabilities to perform in a superior fashion should be detailed.
The CCSRP will appoint a Project Oversight Group (POG) to oversee the project. The CCSRP is responsible for recommending the proposal to be funded. Input from other knowledgeable individuals also may be sought, but the CCSRP will make the final recommendation, subject to SOA leadership approval. The SOA's Research Project Manager will provide staff actuarial support.
Any questions regarding this RFP should be directed to Rob Montgomery, SOA Research Project Manager (phone: 740-258-2977; email: firstname.lastname@example.org.
Notification of Intent to Submit Proposal
If you intend to submit a proposal, please e-mail written notification by April 15, 2021 to Erika Schulty.
Submission of Proposal
Please e-mail a copy of the proposal to Erika Schulty.
Proposals must be received no later than May 15, 2021. It is anticipated that all proposers will be informed of the status of their proposal by end of May to Early June 2021.
Note: Proposals are considered confidential and proprietary.
The selection of a proposal is conditioned upon and not considered final until a Letter of Agreement is executed by both the Society of Actuaries and the researcher.
The Society of Actuaries reserves the right to not award a contract for this research. Reasons for not awarding a contract could include, but are not limited to, a lack of acceptable proposals or a finding that insufficient funds are available. The Society of Actuaries also reserves the right to redirect the project as is deemed advisable.
The Society of Actuaries plans to hold the copyright to the research and to publish the results with appropriate credit given to the researcher(s).
The Society of Actuaries may choose to seek public exposure or media attention for the research. By submitting a proposal, you agree to cooperate with the Society of Actuaries in publicizing or promoting the research and responding to media requests.
The Society of Actuaries may also choose to market and promote the research to members, candidates and other interested parties. You agree to perform promotional communication requested by the Society of Actuaries, which may include, but is not limited to, leading a webcast on the research, presenting the research at an SOA meeting, and/or writing an article on the research for an SOA newsletter.