221219 Comments Climate Risk FIO FINAL


January 04, 2023


The U.S. Chamber of Commerce (“the Chamber”) appreciates the opportunity to further respond to the Federal Insurance Office’s (“FIO”) request for comment on your proposed collection (“Proposal”) of climate-related financial risk data. In the Chamber’s November 2021 response to FIO’s request for information (RFI)1 on the insurance sector and climate-related financial risks, we noted the significant and ongoing engagement we have conducted with our members and other stakeholders for nearly a decade to promote initiatives to address climate challenges.

In addition, we noted that the insurance industry has been forward leaning in addressing the impacts of climate change, taking voluntary actions to address climate-related financial risk, including changes in underwriting, promoting resilience and pre-disaster mitigation for at-risk assets insured by commercial P&C, and changes in long-term investment strategy.3 The Chamber is committed to market centered solutions to these challenges and welcomes the opportunity to engage in constructive collaboration towards these ends

221219 Comments Climate Risk FIO FINAL