16/12/2024

Findings of the IFoA Climate and Sustainability Scenarios Committee

Findings of the IFoA Climate and Sustainability Scenarios Committee Nick Spencer, Chair of the IFoA’s Climate and Sustainability Scenarios Committee, introduces the committee’s findings and recommendations

Last year, at a Staple Inn iNED event reviewing the recent ‘The Emperor’s New Climate Scenarios’, there was broad acceptance of the report’s finding. But it accompanied a widespread lament that boards and their advisors didn’t seem aware of the challenges and certainly not engaged in the issues.

Rather than just lamenting, we resolved to follow this up, working with the IFoA’s Council and Sustainability Board to create the Climate and Sustainability Scenarios Committee.

The committee’s objective was “to consider the appropriate responses and plan of action to address the potential that many of the industry standard climate and sustainability scenarios may not be suitable for the regulatory and reporting purposes they are being used for. It will bring these matters to the attention of the appropriate regulators with the aim of developing suitable remedies.”

Combining Council, Sustainability Board, the executive and senior volunteers, the committee convened roundtables including representatives from BoE, FCA, TPR, FRC, Lloyds of London, and DWP (held under Chatham House rule, with attendees speaking from a personal perspective).

 

Summary of findings and recommendations

Below you can read the committee’s:

In brief, the committee felt that the capabilities outlined in the recent IFoA Risk Alert form an excellent basis for all financial services boards and professionals to follow. This would require boards and professionals to understand climate scenarios’ challenges and limitations, communicate these clearly, and consider the implications of worse-case scenarios that may be much more severe.

As such, we believe the competency and capabilities of our financial services will be much enhanced leading to greater resilience and adaptability to the impacts of climate change. Further, better understanding and communication will reduce consumer detriment risks, improve the management of climate-related risks, and reduce risks of greenwashing miscommunication.

Our recommendations include writing with our findings to the regulators (now completed) and encouraging ongoing Sustainability Board dialogue with them. We recommended the IFoA’s Education Committee work closely with the Regulatory Board to understand how it can best support the understanding of actuaries as outlined in the Risk Alert.

We also recommended further investigations on potential prudential gaps in our regulatory oversight and helping convene academics and climate scientists to understand potential gaps in scenario projections on an ongoing basis.

 

A personal point of view

Stepping away from the committee’s work, from a personal point of view, I have been taken by the increasing work on the inter-connectedness of risks, with an example mapping highlighted in the ‘Climate Scorpion’ report. Interconnectedness, system-thinking and system-perspectives were also regularly repeated themes at the recent IFoA’s Sustainable Investment Conference in October.

I’m excited by the new vistas that are opening up for actuarial and risk work – embracing complexity within short-term, ‘decision-useful’ risk maps and tools. There is a suite of techniques that enhance the actuarial control cycle, help map the complexity and interactions of the system and can be calibrated and quantified into scarily plausible, real-world scenarios. I believe we will soon be asked to extend from thinking solely about climate-related risks to embracing the broader interactions with nature and society.

Addressing the systemic risks from climate change, and the broader sustainability challenge, is a complex multifaceted problem. Raising understanding and awareness of limitations in current models is critical, especially given the significant gap (gulf?) between scenario projections and the latest climate science.

But this is only part of the ongoing conversations and upskilling we will require. And it’s a huge opportunity. Once integrated with a systems-perspective, the actuarial mindset is almost certainly one of the best placed to understand the implications of the modelling strengths and weaknesses, and help guide and advise their clients through the complexity and uncertainties of our future paths.

I’m looking forward to seeing these approaches embedded into our core skillsets. The demands and challenges of sustainability stretch us individually and collectively, but this also makes it an exciting opportunity for the whole profession.

Finally, I would like to thank my fellow committee members Sandy Trust (original Chair and then Deputy Chair), Wendy Walford, Mike Clark, Martin Ettles and Caroline Winchester for all their insights, hard work and, particularly, for their forbearance during all the times when I was hard-driving responses and deadlines.

 

Findings

  • Recent IFoA member-led research highlighted the challenges and limitations within commonly used published climate scenarios. The June 2024 IFoA climate scenario Risk Alert highlighted risks to actuarial advice if these limitations were not understood and appropriately communicated.
  • The IFoA Climate and Sustainability Scenarios Committee organised a series of roundtables and discussions with UK financial service regulators to review the implications of the research findings. The roundtable participants widely agreed that the IFoA Risk Alert articulated an appropriate level of competencies to achieve good climate risk governance within organisations and at executive boards. However, there was concern that the level of understanding and competencies across UK financial service organisations could fall short of these expectations.
  • Weak management of climate risk threatens the stability and security of financial service firms and the likelihood of an orderly financial transition. Furthermore, gaps in the technical understanding of models can lead to misstatements in firms’ disclosures and customer information. Both of these could potentially lead to adverse customer experience. There is a brief window to improve competencies and thus mitigate this risk before the year-end disclosures are prepared at the start of 2025.
  • Addressing the systemic risks from climate change is a complex multifaceted problem. Alongside highlighting the current regulatory approaches, the discussions also identified other potential prudential and systemic gaps. These gaps highlight some of the limitations of the regulatory landscape in addressing the externalities that arise, from valuing and managing nature’s worth to the full financial impacts from climate change. There is no body that is obviously responsible for identifying these gaps nor highlighting potential actions or changes that may mitigate them.

 

Recommendations

  • The IFoA members work across the full financial ecosystem. This enables the IFoA to act in the public interest and to highlight the systemic issues identified through member-led research and outreach programmes. We recommend the IFoA President write to the financial services regulators with this committee’s findings. This would highlight the attendees concern of potential gaps in financial firms’ competencies for good climate risk governance. This reflects the direct concern of potential adverse societal outcomes from gaps in the technical understanding and use of climate models. Moreover, weaknesses in climate risk governance and technical understanding leads to risks of miscommunication (“greenwashing”) in customer communications and public disclosures.
  • These findings do not have simple solutions and will require a consistent and sustained commitment from the IFoA. We recommend that this be led by the IFoA Sustainability Board, which could expand its remit to take responsibility for a continued member-interest dialogue on climate scenario analysis with these regulators, commissioning additional research and working groups, convening future roundtables as appropriate, and annual reporting to both the Council and IFoA Board on progress and any further recommendations, as well as to the Regulatory Board in terms of any professional regulation and conduct issues.
  • Subject to the capacity of the volunteer groups and policy team, the committee recommends further research into the potential prudential and systemic gaps that it identified. Similarly, if possible, it also recommends convening appropriate expert climate academics to help formally, independently and regularly review widely-used climate scenarios to highlight potential gaps and disconnects from current science.
  • Finally, the committee recommends that the IFoA Education Committee liaise with both the Regulatory Board and Sustainability Board on ways to support competency of members in this area.
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