Currently only 15 percent of U.S. insurers surveyed discussed climate change in 10K filings, compared to 100 percent of electric utilities and 78 percent of oil companies. Citing these statistic as creating a challenge for regulators wanting to determine whether the insurance industry is prepared for the risks posed by climate change, the National Association of Insurance Commissioners (NAIC) voted to require large insurers to disclose the strategies they are using to address climate change-related risks. The Insurer Climate Risk Disclosure Survey (download PDF:305KB) mandates that insurance companies inform their respective state regulators of the financial risks they foresee from climate change and what steps they are taking to address those risks. NAIC's new disclosure requirement consists of responding to an eight-part questionnaire that focuses on how insurance companies are assessing and addressing climate change. Wisconsin Commissioner Sean Dilwig recently told Congress that the Insurer Climate Change Disclosure Survey "represents a good first approach" to "begin to understand how climate change is affecting the risks that are underwritten every day." But, he also said the questionnaire is only a "starting point and the (NAIC Climate Change) Task Force recognizes that as the science behind climate modeling evolves, so must the approach of regulators." For more information about these new disclosure requirements, Gardere prepared a client alert on the NAIC Climate Change Disclosure Survey.