On November 15, the New York Department of Financial Services (NYDFS) issued final guidance for New York domestic insurers on taking a comprehensive approach to identifying, managing and reporting climate change financial risk (Final Guidance). The Final Guidance described the distinctive nature of climate risk, emphasizing its far-reaching breath and magnitude and the inability to use the past as an accurate predictor of the climate future.

In the Final Guidance, the DFS stated its expectation that New York domestic insurers would (1) "integrate consideration of climate risk into it governance structure"; (2) consider climate risks in business decisions using appropriate time lines; (3) "incorporate climate risk into the insurer's existing financial risk management"; (4) use scenario analysis to assess and manage climate change risk; and (5) publicly disclose its climate change risk. (Final Guidance at p. 3). The guidance set an Aug. 15, 2022 deadline for New York domestic insurers to adopt a written climate risk policy and to put in place management systems at the board and operations levels to identify and incorporate climate change financial risk into Enterprise Risk Management (ERM) systems.