1) Oct 21 -- The Federal Insurance Office (FIO) of the U.S. Department of the Treasury (Treasury) intends to request approval from the Office of Management and Budget (OMB) for the collection of information from certain property & casualty (P&C) insurers regarding their current and historical underwriting data on homeowners' insurance, as described below. The proposed data collection will assist FIO's assessment of climate-related exposures and their effects on insurance availability for policyholders, including whether climate change may create the potential for any major disruptions of private insurance coverage in regions of the country particularly vulnerable to climate change impacts. FIO will also seek to assess any related effects on insurance affordability for policyholders. Submit comments on or before December 20, 2022.
On May 20, 2021, President Biden issued an Executive Order on Climate-related Financial Risk, Exec. Order No. 14030 (E.O. 14030). E.O. 14030 emphasizes the important role that the insurance sector can play. In this regard, it states the Secretary of the Treasury shall task FIO “to assess climate-related issues or gaps in the supervision and regulation of insurers, including as part of the [Financial Stability Oversight Council's] analysis of financial stability, and to further assess, in consultation with States, the potential for major disruptions of private insurance coverage in regions of the country particularly vulnerable to climate change impacts.” . . .
In response to E.O. 14030, one of FIO's climate-related priorities is to assess the potential for major disruptions of private insurance coverage in U.S. markets particularly vulnerable to climate change impacts. FIO intends to further this work by proposing to collect data from certain U.S. insurance entities to analyze property & casualty (P&C) insurers' current and historical weather-related exposures from physical risks. Physical risks refer to “the harm to people and property arising from acute, climate-related disaster events such as hurricanes, wildfires, floods, and heatwaves as well as longer-term chronic phenomena such as higher average temperatures, changes in precipitation patterns, sea level rise, and ocean acidification.”
Physical risks can affect both the asset and liability side of an insurer's balance sheet. . . .
FIO is proposing to collect data relating to insurers' underwriting metrics and related insurance policy information. The proposed data is needed in order for FIO to identify and more accurately assess the financial impact of weather-related events on insurers' exposures and underwriting over time. FIO's analysis would assess insurance availability and its effects on policyholders, particularly in regions of the country with the potential for major disruptions of private insurance coverage due to climate-related disasters. This proposed data collection would also allow FIO to analyze the affordability of insurance, both nationwide and in regions of the country with the potential for major disruptions of private insurance coverage due to climate-related disasters. FIO's analysis would not focus on measuring the impact on earnings or capital to assess profitability or solvency of individual insurance companies.
FIO's proposed data collection leverages the format of data regularly reported on the annual statutory filings submitted by U.S. insurers to the insurance regulators in the 50 states, the District of Columbia (DC), and the five U.S. territories (collectively, State Insurance Regulators). However, FIO's proposed collection differs from statutory filings in three important areas: (1) the collection of data at a more granular level (i.e., aggregated by ZIP Code rather than at a U.S. state level), (2) the collection of underwriting data primarily on an Accident Year basis (rather than Calendar Year basis), and (3) the proposed inclusion of certain, limited data elements not collected on statutory filings (e.g., replacement values, deductibles, and coverage limits). . . .
FIO's proposed data collection attempts to limit the burden of data collection on the insurance industry while also providing FIO with sufficient data to achieve its assessment of climate risks as set forth in this notice. Below, this section describes the rationale and main elements of FIO's proposed data collection, which include: (1) a focus on insurer underwriting, (2) insurance lines of business, (3) insurers, (4) data elements, (5) reporting framework, (6) reporting period, (7) geographic granularity, (8) geographic scope, and (9) reinsurance impact.
FIO's proposed analysis of physical risk would focus on P&C insurers' underwriting. For its analysis, FIO proposes to collect insurance underwriting data from insurers constituting the top writers (by premiums written on a national basis) in the homeowners' multi-peril line of business, as well as insurers with the greatest market share in certain states that are potentially vulnerable to climate-related disasters.
FIO proposes to collect data from: (1) nationwide insurers writing above a premium threshold of $100 million in 2021 homeowners' insurance premiums; and (2) additional insurers in order to achieve an 80 percent market share threshold in each of 10 states that are potentially the most vulnerable to climate-related disasters (Potential Climate-Vulnerable States). (See also discussion of U.S. state selection in “Insurers” below.) These two categories collectively cover 213 insurance entities (the Representative Sample Insurers) who are domiciled in 34 states . . . .
FIO proposes collecting underwriting data for the Representative Sample Insurers. This data would include information regarding claims, premiums, and losses that correspond to data fields reported by U.S. insurers to State Insurance Regulators in annual filings, as well as additional data elements not collected on statutory filings (e.g., premium renewals, replacement values, deductibles, and coverage limits). FIO proposes requesting five years of underwriting data, 2017 through 2021 (Reporting Period), on an Accident Year reporting basis to evaluate underwriting trends, including before and after periods corresponding to weather-related events. Finally, and in line with its statutory authorities, FIO proposes collecting data at a ZIP Code level for all U.S. ZIP Codes applicable to the Representative Sample Insurers in order to conduct a granular, nationwide assessment.
Data would be collected from insurers in a specified Excel template to be provided by FIO (Template). A copy of the proposed Template is available at https://home.treasury.gov/system/files/311/FIO-Proposed-Climate-Data-Call-Template.xlsx
and instructions for filling out the template are available at https://home.treasury.gov/system/files/311/FIO-Proposed-Climate-Data-Call-Instructions.pdf
Under the proposed collection, each of the Representative Sample Insurers would need to aggregate and report the data requested by the template at a ZIP Code level for all of the policies that they have written nationwide during the Accident Year Reporting Period.
To ensure efficient and accurate completion of the forms, FIO is requesting public feedback on the content of the proposed data collection outlined in this Notice and Request for Comments and on associated matters. In particular, FIO seeks comments on the following issues:
1. Focus on Underwriting: FIO proposes to focus this data collection on insurers' underwriting for homeowners' policies to assess the impact of physical risk on the availability of insurance coverage for policyholders as well as whether the available insurance coverage is affordable for policyholders. Please provide your views on FIO's focus on insurers' underwriting.
2. Selection of Insurance Lines: FIO proposes collecting information on homeowners' multi-peril policies. Should FIO consider data collection for any other lines of business? To what extent should FIO's assessment include NFIP policies and private flood insurance policies?
3. Selection of Insurers: FIO proposes selecting insurers that meet either of the following criteria: (1) insurers writing $100 million or more in annual homeowners' insurance premiums in 2021 or (2) additional insurers that would allow FIO to capture at least 80 percent in each of the 10 Potential Climate-Vulnerable States identified above. Please provide your views on the appropriateness of these thresholds and whether they should be modified.
4. Inclusion of Data Elements: The data template includes elements related to insurers' policies, claims, premiums, and losses. Are there any additional data elements you would propose to include? Are there any data elements you would propose to exclude? How should FIO's analysis consider other potential elements such as additional living expenses or reinsurance?
5. Use of Accident Year Information: FIO proposes collecting ZIP Code level information in the Template on an Accident Year basis, rather than Calendar Year basis. Please provide any additional comments on FIO's proposed use of an Accident Year reporting framework for its proposed data collection.
6. Selection of Reporting Period: FIO proposes collecting data for each year from 2017 through 2021. Please provide your views on the appropriateness of this reporting period and whether it should be modified by FIO.
7. Collection at ZIP Code level: Please provide your views on FIO's proposal to collect data at a ZIP Code level.
8. Collection across all Jurisdictions: FIO is proposing to collect nationwide data for identified insurers to allow for a nationwide understanding and assessment of U.S. insurance markets that may be affected by climate-related events. Please provide your views on FIO's proposal to collect nationwide data from certain insurers.
9. Methodology for Selection of Potential Climate-Vulnerable States: FIO used the FEMA National Risk Index to select the ten states that potentially may be vulnerable to climate-related disasters. Please provide your views on FIO's use of the National Risk Index to select the Potential Climate-Vulnerable States. Are there other data source(s) that FIO should consider in this methodology?
10. Burden Estimate: Please provide your views on whether FIO's burden estimate is accurate and whether there are further ways to minimize the burden of this proposed data collection.
11. Annual Collection: Please provide your views on whether FIO should collect this information from U.S. insurers on an annual basis.
12. Analysis of Availability: Please provide your views on how FIO should assess the impact of climate-related risks on the availability of insurance.
13. Analysis of Affordability: Please provide your views on how FIO should assess the impact of climate-related risks on the affordability of insurance.
14. Additional Comments: Please provide any additional comments that may be relevant to FIO's proposed data collection and analyses.
2) Oct 18 -- Treasury’s Federal Insurance Office Takes Important Step to Assess Climate-related Financial Risk – Seeks Comment on Proposed Data Call [press release]
Request for public comments: https://home.treasury.gov/system/files/311/FIO-Proposed-Climate-Data-Call-Federal-Register-Notice.pdf
Proposed data collection template: https://home.treasury.gov/system/files/311/FIO-Proposed-Climate-Data-Call-Template.xlsx
Instructions for the proposed data collection: https://home.treasury.gov/system/files/311/FIO-Proposed-Climate-Data-Call-Instructions.pdf
FIO’s August 2021 request for information: https://home.treasury.gov/policy-issues/financial-markets-financial-institutions-and-fiscal-service/federal-insurance-office/reports-notices
Press release: https://home.treasury.gov/news/press-releases/jy1030