During the NAIC's May meeting, insurance industry representatives said that total disclosure would reveal proprietary company information and could also be a basis for legal action.

Ceres said the aim of the disclosures must be "substantive, specific and public," and the current proposal--making some of the answers confidential--would defeat that purpose.

"We urge the working group to revise the current proposal by making the responses to all questions, including questions seven, eight and nine, public information," the group said in its comments.

"If the working group is unwilling to make the responses to all questions public, we then urge the working group to take no action on climate risk disclosure and leave any such activity to individual states," said Ceres.

A spokeswoman for the Kansas City, Mo.-based NAIC said the comments submitted by Ceres are part of general comments requested by the working group on the proposed model regulation.

The working group will be meeting at the end of this month during the NAIC's national meeting to discuss these and other comments. At that time, it would decide what the working group's next move would be, she said. There would be no additional comment at this time, she added.

The third draft version in contention, under questions seven, eight and nine asks insurers what they know about how global climate change will affect them and their solvency, the geographical location of the impact, and what actions they have taken to protect their capital positions.

The working group noted that the goal of the form is to provide regulators, insurers and the public "with substantive information about the risks posed by climate change to insurers and the actions insurers are taking in response to their understanding of climate change risk."