Last month, the Federal Insurance Office (FIO) of the Treasury Department issued a Notice of Information Collection and Request for Comment (NIC/RFC) on its planned data collection of climate-related financial risk information associated with U.S. homeowners’ insurance underwriting. In its latest regulatory action, the FIO sought the approval of the Office of Management and Budget (OMB) to collect six years’ worth of homeowners’ insurance underwriting data from an estimated 240 homeowners’ insurance entities, domiciled across 29 states.

The proposal is one element of the Biden administration’s strategy to address climate-related financial risks and sets forth a plan to solicit information from insurers with at least a one-percent stake in the U.S. homeowners’ insurance market, as determined by each carrier’s 2022 percentage of direct written premium. Each insurer will be instructed to share detailed ZIP code-level data for the insurance years from 2017 to 2022. If approved, the data call will collect loss- and claims-related data, along with premium-related data and policy information.

Earlier this week, PIA submitted comments setting forth its concerns about both the efficacy and appropriateness of the data call, which include but are not limited to:

• The burden it will impose on small or regional insurers
• Its poor design for nationwide analysis at a ZIP code level
• Its duplication of existing state insurance regulatory efforts to gather similar and more useable data
• Its comparative lack of understanding of state insurance regulatory reporting requirements
• Its noncompliance with existing federal law, which obligates the FIO to request data from state insurance regulators before demanding it directly from insurers

PIA will continue to monitor the FIO’s activity on climate risk and the OMB’s response to its request for approval, and we will continue to urge the FIO to withdraw its proposed data call.