Notice2022-22880
Agency Information Collection Activities; Proposed Collection; Comment Request; Federal Insurance Office Climate-Related Financial Risk Data Collection
Primary source
Metadata and text below are from the Federal Register, a public-domain U.S. government work. Always verify the official published version before relying on it for any legal matter.
Published
October 21, 2022
Issuing agencies
Treasury Department
Abstract
Pursuant to the Federal Insurance Office Act of 2010 (FIO Act), 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. The Paperwork Reduction Act of 1995 (PRA) requires federal agencies to publish a notice in the Federal Register concerning each proposed collection of information before submission to OMB, and to allow 60 days for public comment in response to the notice. This notice complies with that requirement.
Full Text
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<title>Federal Register, Volume 87 Issue 203 (Friday, October 21, 2022)</title>
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[Federal Register Volume 87, Number 203 (Friday, October 21, 2022)]
[Notices]
[Pages 64134-64141]
From the Federal Register Online via the Government Publishing Office [<a href="http://www.gpo.gov">www.gpo.gov</a>]
[FR Doc No: 2022-22880]
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DEPARTMENT OF THE TREASURY
Agency Information Collection Activities; Proposed Collection;
Comment Request; Federal Insurance Office Climate-Related Financial
Risk Data Collection
AGENCY: Federal Insurance Office, Departmental Offices, Treasury.
ACTION: Notice and request for comments.
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SUMMARY: Pursuant to the Federal Insurance Office Act of 2010 (FIO
Act), 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. The Paperwork Reduction Act of 1995
(PRA) requires federal agencies to publish a notice in the Federal
Register concerning each proposed collection of information before
submission to OMB, and to allow 60 days for public comment in response
to the notice. This notice complies with that requirement.
DATES: Submit comments on or before December 20, 2022.
ADDRESSES: Submit comments electronically through the Federal
eRulemaking Portal: <a href="http://www.regulations.gov">http://www.regulations.gov</a>, or by mail to the
Federal Insurance Office, Attn: Elizabeth Brown, Senior Insurance
Regulatory Policy Analyst, <a href="/cdn-cgi/l/email-protection#a2e7cecbd8c3c0c7d6ca8ce0d0cdd5cce2d6d0c7c3d1d7d0db8cc5cdd4"><span class="__cf_email__" data-cfemail="3f7a5356455e5d5a4b57117d4d5048517f4b4d5a5e4c4a4d4611585049">[email protected]</span></a>, (202) 597-2869
or Silab Mohanty, Senior Insurance Regulatory Policy Analyst,
<a href="/cdn-cgi/l/email-protection#bdeed4d1dcdfd5dcd9cfdc93f0d2d5dcd3c9c4fdc9cfd8dccec8cfc493dad2cb"><span class="__cf_email__" data-cfemail="ca99a3a6aba8a2abaeb8abe487a5a2aba4beb38abeb8afabb9bfb8b3e4ada5bc">[email protected]</span></a>, (202) 945-7062, Room 1410 MT,
Department of the Treasury, 1500 Pennsylvania Avenue NW, Washington, DC
20220. Because postal mail may be subject to processing delays, it is
recommended that comments be submitted electronically. If submitting
comments by mail, please submit an original version with two copies.
Comments concerning the proposed data collection forms and collection
process should be captioned as ``FIO Climate-Related Financial Risk
Data Collection Comments.'' Please include your name, group
affiliation, address, email address, and telephone number(s) in your
comment. Where appropriate, a comment should include a short Executive
Summary (no more than five single-spaced pages).
FOR FURTHER INFORMATION CONTACT: Elizabeth Brown, Senior Insurance
Regulatory Policy Analyst, <a href="/cdn-cgi/l/email-protection#0b4e6762716a696e7f63254979647c654b7f796e6a787e7972256c647d"><span class="__cf_email__" data-cfemail="185d747162797a7d6c70365a6a776f76586c6a7d796b6d6a61367f776e">[email protected]</span></a>, (202) 597-
2869, or Silab Mohanty, Senior Insurance Regulatory Policy Analyst,
<a href="/cdn-cgi/l/email-protection#edbe84818c8f858c899f8cc3a082858c839994ad999f888c9e989f94c38a829b"><span class="__cf_email__" data-cfemail="e7b48e8b86858f86839586c9aa888f8689939ea7939582869492959ec9808891">[email protected]</span></a>, (202) 945-7062 (these telephone
numbers are not toll-free). Persons who have difficulty hearing or
speaking may access these numbers via TTY by calling the toll-free
Federal Relay Service at (800) 877-8339.
SUPPLEMENTARY INFORMATION:
Background
Under the FIO Act, FIO's authorities include monitoring all aspects
of the insurance sector, including identifying issues or gaps in the
regulation of insurers that could contribute to a systemic crisis in
the insurance sector or the U.S. financial system. FIO's authorities
also include monitoring ``the extent to which traditionally underserved
communities and consumers, minorities (as such term is defined in
section 1204(c) of the Financial Institutions Reform, Recovery, and
Enforcement Act of 1989 (12 U.S.C. 1811 note)), and low- and moderate-
income persons have access to affordable insurance products regarding
all lines of insurance, except health insurance.'' \1\ In carrying out
its duties, FIO is authorized to collect data and information on and
from the insurance sector, including through the use of subpoenas. FIO
is also authorized to analyze and disseminate data and information and
issue reports on all lines of insurance, except health insurance.\2\
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\1\ FIO Act, 31 U.S.C. 313 (c)(1)(B).
\2\ FIO Act, 31 U.S.C. 313 (d)-(e).
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On May 20, 2021, President Biden issued an Executive Order on
Climate-related Financial Risk, Exec. Order No. 14030 (E.O. 14030).\3\
As part of its Government-wide instruction to study and take actions in
response to climate-related financial risks, 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
[[Page 64135]]
particularly vulnerable to climate change impacts.'' \4\ On August 31,
2021, FIO outlined its priorities with regard to climate-related
financial risk in a request for information (RFI) on the Insurance
Sector and Climate-Related Financial Risks.\5\ In the RFI, FIO cited
the need for consistent, comparable, and granular data to work on its
climate-related priorities.\6\ FIO's climate-related work will be part
of sequential and capacity-building efforts. The initial steps are
intended to consolidate foundational knowledge that can be used in
future years to develop more comprehensive approaches to address
climate-related financial risks.
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\3\ Executive Order on Climate-related Financial Risk, E.O. No.
14030, 86 FR 27967 (May 20, 2021), <a href="https://www.federalregister.gov/documents/2021/05/25/2021-11168/climate-related-financial-risk">https://www.federalregister.gov/documents/2021/05/25/2021-11168/climate-related-financial-risk</a> (E.O.
14030).
\4\ See Section 3(b)(i) in E.O. 14030. E.O. 14030 at 27968.
\5\ Federal Insurance Office Request for Information on the
Insurance Sector and Climate-Related Financial Risks, 86 FR 48814
(August 31, 2021), <a href="https://www.federalregister.gov/documents/2021/08/31/2021-18713/federal-insurance-office-request-for-information-on-the-insurance-sector-and-climate-related">https://www.federalregister.gov/documents/2021/08/31/2021-18713/federal-insurance-office-request-for-information-on-the-insurance-sector-and-climate-related</a> (FIO RFI).
\6\ 86 FR 48814 at 48815.
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Overview of Analysis
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.\7\ 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.'' \8\
Physical risks can affect both the asset and liability side of an
insurer's balance sheet.\9\ On the asset side, insurers may be impacted
by impairments and market declines in the value of investments held in
securities of companies exposed to the physical effects of climate
change and in real estate-related collateral, such as commercial
property loans or agricultural-related assets. On the liability side,
increases in the frequency, severity, and geographical distribution of
weather-related events due to climate change could lead to higher
direct losses from property damage, as well as indirect losses such as
from business interruption and higher reinsurance costs. Additionally,
severe weather-related events may create a potential protection gap for
policyholders, which is generally understood to be the difference
between the amount of insurance that is economically beneficial and the
amount of insurance actually purchased, i.e., when the policyholder is
uninsured or underinsured.\10\
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\7\ 86 FR 48814 at 48815.
\8\ Financial Stability Oversight Council, Report on Climate-
related Financial Risk (2021), 12, <a href="https://home.treasury.gov/system/files/261/FSOC-Climate-Report.pdf">https://home.treasury.gov/system/files/261/FSOC-Climate-Report.pdf</a> (FSOC Climate Report).
\9\ When an insurer underwrites a policy and receives premiums,
it undertakes a potential obligation to settle valid claims. The
estimate of the insurer's obligation to pay future claims is
reflected as a liability on the insurer's balance sheet.
\10\ See, e.g., The Geneva Association, The Global Insurance
Protection Gap: Assessment and Recommendations (2014), 7, <a href="https://www.genevaassociation.org/sites/default/files/research-topics-document-type/pdf_public/ga2014-the_global_insurance_protection_gap_1.pdf">https://www.genevaassociation.org/sites/default/files/research-topics-document-type/pdf_public/ga2014-the_global_insurance_protection_gap_1.pdf</a>.
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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). Further explanation regarding FIO's proposed data collection
and the specific data items being request is provided below.
Proposed Scope of Data Collection
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.
Summary
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.\11\
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\11\ FIO is using the term ``climate-related disasters'' to
refer to the type of weather-related events (such as wildfires,
floods, hurricanes, etc.) that may be produced or exacerbated by
climate change, as distinct from non-weather related, natural events
(such as earthquakes and tsunamis). References to ``catastrophic
events'' may include both weather-related and non-weather-related
events; similar (or synonymous) terms used by the insurance industry
include ``natural catastrophes'' and ``natural disasters.''
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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: Alabama, Arkansas, California, Connecticut,
Delaware, Florida, Georgia, Illinois, Indiana, Iowa, Kansas, Kentucky,
Louisiana, Massachusetts, Michigan, Minnesota, Mississippi, Missouri,
Nebraska, New Hampshire, New Jersey, New York, North Carolina, North
Dakota, Ohio, Oklahoma, Oregon, Pennsylvania, Rhode Island, Tennessee,
[[Page 64136]]
Texas, Vermont, Washington, and Wisconsin.\12\
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\12\ An insurance company is said to be ``domiciled'' in the
state that issued its primary license. Once licensed in one state,
the company may seek licenses in other states and most insurers
write policies in multiple states.
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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 <a href="https://home.treasury.gov/system/files/311/FIO-Proposed-Climate-Data-Call-Template.xlsx">https://home.treasury.gov/system/files/311/FIO-Proposed-Climate-Data-Call-Template.xlsx</a> and instructions for filling out the
template are available at <a href="https://home.treasury.gov/system/files/311/FIO-Proposed-Climate-Data-Call-Instructions.pdf">https://home.treasury.gov/system/files/311/FIO-Proposed-Climate-Data-Call-Instructions.pdf</a>. 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.
Underwriting Focus
Insurers face climate-related impacts and risks on both sides of
their balance sheets: underwriting and investments. Consistent with the
FIO Act and with FIO's direct tasking under E.O. 14030, this data
collection focuses on obtaining data necessary to analyze the climate-
related impacts on insurers' underwriting, including any effects on
whether coverage is available to policyholders. Recent data and events
indicate that insurers' underwriting is directly impacted by the
physical risks of weather-related events. For example, by one estimate,
U.S. insured losses from weather-related events totaled $92 billion in
2021 (with uninsured losses reaching an additional $77 billion).\13\
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\13\ ``Facts + Statistics: U.S. Catastrophes,'' Insurance
Information Institute, <a href="https://www.iii.org/fact-statistic/facts-statistics-us-catastrophes">https://www.iii.org/fact-statistic/facts-statistics-us-catastrophes</a>. Losses include those from severe
convective storms, wildfires, drought, heatwaves, flooding, winter
storms, and tropical cyclones.
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Insurance Lines of Business
Multiple lines of insurance may be impacted by climate-related
risks, such as commercial multi-peril, standalone fire, and flood
policies. FIO's proposed data collection focuses on homeowners' multi-
peril insurance because this is the largest personal line of business
impacted directly by weather-related events and is the most relevant in
determining potential effects on policyholders.\14\ Multi-peril
policies provide coverage for more than one hazard and can bundle
together several property and liability insurance lines of business.
Homeowners' multi-peril is often offered by insurers as an all-in-one
insurance coverage package and may include coverage for property damage
from a variety of perils (including wind, hail and fire, loss of use,
theft, mold, explosion, and vandalism; however, flood is typically
excluded).
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\14\ See, e.g., Shanthi Ramnath and Will Jeziorski, ``Homeowners
Insurance and Climate Change,'' Chicago Fed Newsletter, September
2021, <a href="https://www.chicagofed.org/publications/chicago-fed-letter/2021/460">https://www.chicagofed.org/publications/chicago-fed-letter/2021/460</a>.
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Insurers
FIO's selection of insurers was based on two considerations: (1) a
premium threshold of $100 million in 2021 homeowners' insurance
premiums for nationwide insurers and (2) the proposed inclusion of
certain insurers in order to achieve an 80 percent market share
threshold in the Potential Climate-Vulnerable States. FIO aims to
capture a representative share of the U.S. market, particularly in
Potential Climate-Vulnerable States, while minimizing the collection
burden by focusing on the larger insurers.
FIO's proposed premium threshold of $100 million or more in direct
premium written is consistent with the threshold used by 14 states and
DC to designate insurers required to complete the National Association
of Insurance Commissioners (NAIC) Climate Risk Disclosure Survey.
To determine the Potential Climate-Vulnerable States for purposes
of this proposed data collection, FIO used the Federal Emergency
Management Agency (FEMA) data from the National Risk Index (after
reviewing existing sources of climate vulnerability data). FEMA's
National Risk Index is a publicly available dataset on natural hazards
and social vulnerability, with accompanying information on methodology
and data sources, that combines historical county level risk data
across 18 hazard types, though it does not include projections of
future risk due to climate change.\15\ The National Risk Index's
detailed, county level data makes it possible to filter out risks from
non-climate-related events. The National Risk Index also provides
information on the Expected Annual Loss, which is a variable
representing the average economic loss in dollars resulting from
natural hazards each year that is calculated for each hazard type and
quantifies loss for buildings, people, and agriculture.\16\ The
National Risk Index has been used in both the Climate Mapping for
Resilience and Adaptation tool released in September 2022 and by the
National Oceanic and Atmospheric Administration as part of its Billion
Dollar Disaster tool.\17\ In addition, insurance stakeholders have
noted the value of the National Risk Index as a useful tool.\18\ The
NAIC also cited the National Risk Index as a
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\15\ ``Learn More,'' FEMA National Risk Index, <a href="https://hazards.fema.gov/nri/learn-more">https://hazards.fema.gov/nri/learn-more</a>.
\16\ The National Risk Index uses the term Expected Annual Loss;
FIO understands that FEMA's definition may differ from the way
insurers determine expected annual loss within their own business.
\17\ ``Climate Mapping for Resilience and Adaptation,'' U.S.
Global Change Research Program, <a href="https://resilience.climate.gov/">https://resilience.climate.gov/</a>;
``U.S. Billion-Dollar Weather and Climate Disasters,'' National
Centers for Environmental Information, National Oceanic and
Atmospheric Administration, last updated October 11, 2022, <a href="https://www.ncei.noaa.gov/access/billions/">https://www.ncei.noaa.gov/access/billions/</a>.
\18\ Insurance stakeholder comments on the National Risk Index
appeared in response to a FEMA Request for Information on ``FEMA
Programs, Regulations, and Policies,'' which sought feedback to
ensure they are meeting FEMA's mission. See, e.g., Comment from
Reinsurance Association of America (June 23, 2021), <a href="https://www.regulations.gov/comment/FEMA-2021-0011-0168">https://www.regulations.gov/comment/FEMA-2021-0011-0168</a>; Comment from
Insurance Institute for Business and Home Safety (July 19, 2021),
<a href="https://www.regulations.gov/comment/FEMA-2021-0011-0204">https://www.regulations.gov/comment/FEMA-2021-0011-0204</a>.
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[[Page 64137]]
resource for understanding risks.\19\
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\19\ ``Reduce Your Risk Against Climate-Related Losses,'' NAIC,
December 30, 2021, <a href="https://content.naic.org/article/reduce-your-risk-against-climate-related-losses">https://content.naic.org/article/reduce-your-risk-against-climate-related-losses</a>.
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FIO aggregated the National Risk Index's Expected Annual Loss data
across 15 hazards that were determined to be in scope.\20\ Figure 1
shows the 10 states with the highest Expected Annual Loss from those 15
climate-related hazards based on FIO's use of the National Risk Index.
FIO identified the 10 Potential Climate-Vulnerable States as an
additional selection mechanism to ensure sufficient market coverage and
to support more comprehensive geographic coverage. The results indicate
that potential climate impacts are geographically dispersed throughout
the United States.
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\20\ FIO included the following 15 hazards that may experience
impacts from climate change: avalanche, coastal flooding, cold wave,
drought, hail, heat wave, hurricane, ice storm, landslide,
lightning, riverine flooding, strong wind, tornado, wildfire, and
winter weather. Many, but not all, of these hazards may be covered
under homeowners' multi-peril policies (coastal and riverine
flooding are typically covered through separate policies). FIO
excluded earthquakes, volcanic activity, and tsunamis from its
analysis because they are not considered to be impacted by climate
change based on review of both the Fourth National Climate
Assessment, <a href="https://nca2018.globalchange.gov/">https://nca2018.globalchange.gov/</a>, and IPCC's Sixth
Assessment Report, <a href="https://www.ipcc.ch/assessment-report/ar6/">https://www.ipcc.ch/assessment-report/ar6/</a>.
Figure 1--Top 10 Potential Climate-Vulnerable States
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1......................................... Texas.
2......................................... California.
3......................................... Florida.
4......................................... Louisiana.
5......................................... North Carolina.
6......................................... New Jersey.
7......................................... Missouri.
8......................................... Illinois.
9......................................... Iowa.
10........................................ Oklahoma.
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Source: ``National Risk Index,'' FEMA, <a href="https://hazards.fema.gov/nri/">https://hazards.fema.gov/nri/</a>;
FIO analysis.
FIO proposes collecting nationwide data from additional insurers
operating in each of these states that do not meet the first
consideration in order to capture at least an 80 percent market share
within each of these 10 states.
Data Elements
The Template requests underwriting income and claims data elements.
While some of the data elements in FIO's proposed collection are
reported by insurers either to statistical agents and/or in the Exhibit
of Premiums and Losses (State Page) and Schedule P of their annual
statutory filings, not all of the fields are reported in one consistent
template, using the same accounting methodology, and at the level of
granularity proposed for this data collection. Annual statutory filings
are done at a national or state level (depending on the element), while
the proposed Template seeks these data elements aggregated at a ZIP
Code level to more accurately assess localized trends and vulnerable
communities, including minority and low- and moderate-income
populations.
FIO's proposed data collection includes financial information from
elements that also may appear in annual statutory filings, including:
insurer identifying information (Template cells C5 through C9), total
year-end net admitted assets (as of 12/31 for year of reporting)
(Template cell C10), total year-end policyholder surplus (as of 12/31
for year of reporting) (Template cell C11), and premiums, claims, and
losses data (Template cells H15 through R15).
FIO's proposed data collections also includes additional fields
that are not in statutory filings, including: (1) the number of policy
in-force exposures (Template cell D15), (2) total dollar value of
coverage for dwelling and/or other structures and personal property
(Template cell E15), (3) total dollar value replacement cost value
(Template cell F15), (4) total dollar amount of insurance deductible
(Template cell G15), and (5) amount of direct premiums written renewed
or retained (Template Cell P15). The data for these fields will help
FIO assess how trends in underwriting and exposures have changed over
time, as well as help provide information on potential protection gaps.
FIO's proposed data collection will only assess exposures that are
directly impacted by weather-related events. Therefore, this data
collection aims to only include data associated with weather-related
hazards, including, but not limited to, convective storms, drought,
hail, hurricanes, ice, sleet, snow, tornados, wildfires, and
windstorms, but would explicitly exclude:
1. Liability exposures (i.e., the proposed data collection will
include only property-related exposures);
2. Flood insurance policies by the National Flood Insurance Program
(NFIP) and private insurers because FEMA, which administers the NFIP,
is conducting its own similar analyses using its publicly available
data, and flood damage is typically not covered by standard homeowners'
multi-peril policies which are the focus of this proposed data
collection; FIO plans to further coordinate with FEMA on flood
insurance data analysis; and
3. Earthquake coverage, intentional losses caused by the
policyholder or his agents (such as arson), acts of terror, or war
since these are not considered weather-related events.
FIO is not proposing at this time to collect data by type of peril.
While loss events may include the impact of multiple perils, there may
not currently be consistency in how insurers maintain or allocate loss
data by peril.
Finally, FIO recognizes that the impact of weather-related events
may also cause an increase in claims related to additional living
expenses. FIO will focus this proposed data collection on claims
associated with physical damage to capture the most direct physical
risk impact of weather-related events. While FIO acknowledges that
additional living expenses claims can account for an increasing portion
of weather-related losses, this form of coverage is not always a
standard part of homeowners' insurance policies. Therefore, the
inclusion of this expense in the analysis could distort metrics
reflecting the direct impact of weather-related events. FIO may
consider the inclusion of additional elements, including such expenses,
in subsequent analyses.
Reporting Framework
FIO proposes to use Accident Year reporting for its data
collection.\21\ In Accident Year reporting, underwriting financial data
is arranged such that the premiums earned in a given year can be
compared with losses associated with claims that occurred in that same
year. In this reporting method, the claims and any subsequent changes
in reserves are attributed back to the period in which the loss event
occurred and not when the loss is reported or paid. Many insurers and
State Insurance Regulators use Accident Year underwriting financial
data to facilitate actuarial analysis for the purposes of rate-making
(or setting policy premiums), reserving, and analyzing losses. In its
data collection, FIO proposes seeking Accident Year underwriting-
related financial data to monitor the development of claims from the
same occurrence throughout the Accident Year.
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\21\ Accident Year reporting is one of two common methods in the
United States of reporting and analyzing insurance underwriting
data; the other is Calendar Year reporting. Under Calendar Year
reporting, an insurer may earn premium or incur a loss from an event
at one point in time but may recognize those losses when claims are
reported and settled at another point in time such as in a
subsequent year. As a result, an insurer's Calendar Year experience
may be considered less reflective of its underwriting experience for
that particular year.
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[[Page 64138]]
Reporting Period
FIO proposes asking for five years of data (2017 through 2021),
primarily on an Accident Year reporting basis to evaluate underwriting
trends, including before and after periods corresponding to weather-
related events. FIO also considered capital planning cycles and
potential time lags in the collection of claims from weather-related
events when considering the time horizon for the proposed data
collection. Additionally, 2017 was a year of record natural catastrophe
losses in the United States, when three of the 10 costliest natural
catastrophes occurred.\22\ Therefore, starting from 2017 should provide
information regarding how underwriting metrics have changed over time
in response to significant catastrophe losses while reducing the burden
of data reporting by focusing the scope of collection on the last five
years of data.
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\22\ Natural catastrophes in this estimate are defined as
natural disasters, which are significant, destructive events with
atmospheric, geological, and hydrological origins (e.g., hurricanes,
earthquakes, and floods), that cause at least $25 million in insured
losses; or 10 deaths; or 50 people injured; or 2,000 filed claims or
homes and structures damaged. Hurricanes Harvey, Irma, and Maria
occurred in 2017 and they were three of the ten costliest natural
catastrophes in the United States, based on data provided by Aon.
See ``Facts + Statistics: U.S. Catastrophes,'' Insurance Information
Institute, <a href="https://www.iii.org/fact-statistic/facts-statistics-us-catastrophes">https://www.iii.org/fact-statistic/facts-statistics-us-catastrophes</a>.
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Geographic Granularity
FIO considered multiple geographic levels at which insurance data
could be collected for this proposed data collection. At the broader
end of the range, FIO considered collecting data from insurance
companies at the national or state level. In the middle of this
spectrum, FIO considered a range of options including collection by ZIP
Code, county, public use microdata area, or census tract. At the
narrower end of the spectrum, FIO considered that collecting data
related to specific latitude and longitude coordinates or building
addresses could help pinpoint specific policies. This section outlines
why FIO's proposed data collection includes collection at a ZIP Code
level.
State-wide information collected on statutory filings would not
provide a sufficient level of granularity for FIO's data analysis.
First, the physical risk assessment related to weather-related events
is complicated and many weather-related events, especially secondary
perils, have localized effects, with risk levels and loss impacts
differing widely within a state. Collecting more granular data than at
a state level would allow FIO to assess the effects of such localized
events on insurance markets. For example, one industry source found
that secondary perils caused more than 70 percent of insured losses
from all natural catastrophes ($81 billion) in 2020.\23\ Secondary
perils are high-frequency, low-to-medium severity weather-related
events that may generate small-to-mid-sized losses, such as severe
convective storms.\24\ The different occurrences of weather-related
events can lead to different potential exposures across a given state.
For example, data collected by the California Department of Insurance
shows that the percentage of dwelling units in high or very high
wildfire zones ranges from less than one percent to more than 82
percent when assessed at a county level.\25\
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\23\ Swiss Re Institute sigma, Natural Catastrophes in 2020:
Secondary Perils in the Spotlight, But Don't Forget Primary-Peril
Risk (2021), 4, <a href="https://www.swissre.com/dam/jcr:ebd39a3b-dc55-4b34-9246-6dd8e5715c8b/sigma-1-2021-en.pdf">https://www.swissre.com/dam/jcr:ebd39a3b-dc55-4b34-9246-6dd8e5715c8b/sigma-1-2021-en.pdf</a>.
\24\ See, e.g., Steve Evans, ``US Severe Weather & Convective
Storm Losses Near $20bn in 2021: Aon,'' Artemis, November 15, 2021,
<a href="https://www.artemis.bm/news/us-severe-weather-convective-storm-losses-near-20bn-in-2021-aon/">https://www.artemis.bm/news/us-severe-weather-convective-storm-losses-near-20bn-in-2021-aon/</a>. Severe convective storms are caused
by warm, moist air rising from the earth, which results in a range
of conditions including drenching thunderstorms with lightning,
tornadoes, hail, or destructive straight-line winds. See, e.g.,
Insurance Information Institute, Severe Convective Storms: Evolving
Risks Call for Innovation to Reduce Costs, Drive Resilience (May
2020), 3, <a href="https://www.iii.org/sites/default/files/docs/pdf/convective_storms_wp_050520.pdf">https://www.iii.org/sites/default/files/docs/pdf/convective_storms_wp_050520.pdf</a>.
\25\ California Department of Insurance, The Availability and
Affordability of Coverage for Wildfire Losses in Residential
Property Insurance in the Wildland-Urban Interface and Other High-
Risk Areas of California: CDI Summary and Proposed Solutions (2017),
Appendix C, <a href="http://www.insurance.ca.gov/0400-news/0100-press-releases/2018/upload/nr002-2018AvailabilityandAffordabilityofWildfireCoverage.pdf">http://www.insurance.ca.gov/0400-news/0100-press-releases/2018/upload/nr002-2018AvailabilityandAffordabilityofWildfireCoverage.pdf</a> (CDI Wildfire
Coverage Report).
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Second, insurers generally price policies based on the risk in a
localized area and such risk assessment may not be uniform for an
entire state. Collecting ZIP Code data will allow FIO to understand
local differences in U.S. state insurance markets, such as those
reflected in premiums, terms and conditions, coverage, and
availability. For example, a report by the Massachusetts Insurance
Division shows differences across Massachusetts in the percentage of
insurance coverage for policyholders from private markets rather than
the residual market, the application of mandatory deductibles for wind
coverage, and the nonrenewal rate.\26\ Additionally, the California
Department of Insurance notes a selective pull back from new business
and renewals in ``certain parts'' of the wildland-urban interface.\27\
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\26\ Massachusetts Division of Insurance, Annual Home Insurance
Report for Calendar Year 2020 (n.d.), 10, 27, 32, <a href="https://www.mass.gov/doc/the-2020-massachusetts-market-for-home-insurance/download">https://www.mass.gov/doc/the-2020-massachusetts-market-for-home-insurance/download</a>.
\27\ CDI Wildfire Coverage Report, 2.
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Third, in order to fulfill its statutory mandate to assess both the
availability of insurance products and the affordability of such
products for vulnerable communities, including minority and low- and
moderate-income populations, FIO plans to consider pairing underwriting
data with demographic data. Demographic data such as socioeconomic
status and average home prices can be readily obtained at a ZIP Code
level. Existing statutory annual statement filings with state level
data assist State Insurance Regulators in the prudential regulation of
insurance companies and are not primarily intended to assess trends
regarding whether such products are available or affordable. Analyzing
ZIP Code information will allow FIO to understand variations in the
availability of insurance within a given state and whether the
available insurance within that state is affordable. These issues could
potentially be obscured by state level averages.
Fourth, using ZIP Code information could be less burdensome for
insurers as they may collect ZIP Code information as part of the
insured property address when underwriting homeowners' multi-peril
policies, making it easier for them to aggregate data at a ZIP Code
level for FIO's proposed data collection.
Fifth, ZIP Codes have unique, numerical identifiers, making them
easier to analyze than other sub-state boundaries such as counties, and
are more stable over time. Historically, county demarcations have
changed more frequently than ZIP Code demarcations.\28\
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\28\ ``Substantial Changes to Counties and County Equivalent
Entities: 1970-Present,'' U.S. Census Bureau, last updated October
8, 2021, <a href="https://www.census.gov/programs-surveys/geography/technical-documentation/county-changes.html">https://www.census.gov/programs-surveys/geography/technical-documentation/county-changes.html</a>.
---------------------------------------------------------------------------
Finally, the use of ZIP Code level data by seven states in certain
circumstances (California, Florida, Illinois, Massachusetts, Missouri,
Tennessee, and Texas) demonstrates the appropriateness of and the
potential benefits of this level of analysis for FIO's climate-related
financial risk analyses. The California Department of Insurance
collected and analyzed data from fire, homeowners' multi-peril, and
private personal auto insurers in California for all ZIP Codes in order
to report on those communities that were considered ``underserved.''
\29\ The
[[Page 64139]]
business overview of Citizens Property Insurance Corporation, the
homeowners residual market insurer in Florida, notes total insured
value by ZIP Code and the Florida Office of Insurance Regulation
provides ZIP Code data in some instances, such as after Hurricane
Michael.\30\ Illinois requires that insurers report ZIP Code level data
for certain lines of business, including homeowners' multi-peril.\31\
The Massachusetts Division of Insurance uses data collected from
certain ZIP Codes to understand differences in premiums, claims and
losses, and cancellations and non-renewals.\32\ The Missouri Department
of Insurance ``requires insurers writing personal lines insurance to
file data by ZIP code, including exposures written, premium written,
loss paid count and losses paid. Data is collected on an annual
basis.'' \33\ Tennessee conducted a catastrophic claims data call in
2016 concerning the November 2016 wildfires in Gatlinburg as well as
two catastrophic claims data calls concerning the impact of tornadoes
that struck the state in 2020.\34\ Each of these three data calls
required insurers to report claims by ZIP Code. Additionally, Texas
initiated a data call following Hurricane Harvey that required insurers
to report several data elements by ZIP Code, including number of
reported claims, number of claims closed with payment, and the total
amount of paid losses.\35\ These non-exhaustive examples illustrate
that insurers are likely to have experience producing and submitting
ZIP Code level information.
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\29\ California Department of Insurance, 2015 Commissioner's
Report on Underserved Communities: Experience Years 2010--2014
(2015), i, <a href="http://www.insurance.ca.gov/0400-news/0200-studies-reports/0800-underserved-comm/upload/CRUC2015ReportFinal-2.pdf">http://www.insurance.ca.gov/0400-news/0200-studies-reports/0800-underserved-comm/upload/CRUC2015ReportFinal-2.pdf</a>.
\30\ Citizens, Corporate Analytics Business Overview (March 31,
2022), 1, <a href="https://www.citizensfla.com/documents/20702/93064/20220331+Business+Overview.pdf/24a9e673-b3e0-c8af-31ca-43f8ca81e24d?t=1652146197003">https://www.citizensfla.com/documents/20702/93064/20220331+Business+Overview.pdf/24a9e673-b3e0-c8af-31ca-43f8ca81e24d?t=1652146197003</a>; ``Hurricane Michael Claims Data,''
Florida Office of Insurance Regulation, <a href="https://www.floir.com/Office/HurricaneSeason/HurricaneMichaelClaimsData.aspx">https://www.floir.com/Office/HurricaneSeason/HurricaneMichaelClaimsData.aspx</a>.
\31\ Illinois Department of Insurance, Instructions for Part
4203--Insurance Data Reporting Requirements: Subpart A: Cost
Containment Reporting (n.d.), 11, <a href="https://insurance2.illinois.gov/regulatory_filings/DataCall/ReportingInstructions.pdf">https://insurance2.illinois.gov/regulatory_filings/DataCall/ReportingInstructions.pdf</a>.
\32\ Massachusetts Division of Insurance, Statistical Supplement
to the 2020 Report on the Massachusetts Market for Home Insurance
(n.d.), 20, 48, 91, <a href="https://www.mass.gov/doc/the-2020-massachusetts-market-for-home-insurance/download">https://www.mass.gov/doc/the-2020-massachusetts-market-for-home-insurance/download</a>.
\33\ ``Statistical Reports,'' Missouri Department of Insurance,
<a href="https://insurance.mo.gov/reports/">https://insurance.mo.gov/reports/</a>.
\34\ Tennessee Department of Commerce and Insurance, ``TDCI
Gathers Insurers' Data For Wildfire Claims Map,'' news release,
December 2, 2016, <a href="https://www.tn.gov/commerce/news/2016/12/2/tdci-gathers-insurers-data-for-wildfire-claims-map.html">https://www.tn.gov/commerce/news/2016/12/2/tdci-gathers-insurers-data-for-wildfire-claims-map.html</a>; State of
Tennessee, Data Call Catastrophic Claims Template, 2016, <a href="https://www.tn.gov/content/dam/tn/commerce/documents/insurance/posts/Ins_TN_Wildfire_Reporting_Data_Call.xlsx">https://www.tn.gov/content/dam/tn/commerce/documents/insurance/posts/Ins_TN_Wildfire_Reporting_Data_Call.xlsx</a>; Tennessee Department of
Commerce and Insurance, Notice of Catastrophic Claims Data Call
Related to the March 2nd & 3rd Tornadoes (March 5, 2020), <a href="https://www.tn.gov/content/dam/tn/commerce/documents/insurance/bulletins/030520_Claims_Data_Call.pdf">https://www.tn.gov/content/dam/tn/commerce/documents/insurance/bulletins/030520_Claims_Data_Call.pdf</a>; Tennessee Department of Commerce and
Insurance, Notice of Catastrophic Claims Data Call Related to the
April 12th & 13th Tornadoes (April 21, 2020), <a href="https://www.tn.gov/content/dam/tn/commerce/documents/insurance/bulletins/042120_April_12-13_Tornadoes_Data_Call.pdf">https://www.tn.gov/content/dam/tn/commerce/documents/insurance/bulletins/042120_April_12-13_Tornadoes_Data_Call.pdf</a>.
\35\ Texas Department of Insurance, Hurricane Harvey Data Call:
Data through September 30, 2018 (April 25, 2019), <a href="https://www.tdi.texas.gov/reports/documents/harvey-dc-04252019.pdf">https://www.tdi.texas.gov/reports/documents/harvey-dc-04252019.pdf</a>.
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Geographic Scope
FIO is proposing to collect data from Representative Sample
Insurers for all U.S. ZIP Codes in which they operate, for a number of
reasons. First, consistent with FIO's statutory authorities, it would
allow FIO to develop a nationwide understanding and assessment of how
U.S. markets are being affected by climate-related events.
Additionally, an individual U.S. state may have localized areas of
potential risk to weather-related events that are obscured by state
average metrics. Second, nationwide data allows FIO to compare relevant
data for insurance markets that are in geographic areas with varying
degrees of exposure to weather-related events. Nationwide data will
also provide a national reference group that may allow FIO to control
for trends such as rising home replacement costs that can cause
disruption in insurance markets but are not directly tied to climate
impacts.
Reinsurance Impact
FIO is excluding the impact of reinsurance from this proposed data
collection. Allocating reinsurance data for the various types of
reinsurance (including treaty and facultative) to policy and ZIP Code
level would require a consistency of assumptions across reporting
insurers which is not currently available. To avoid potential double
counting, all reporting will focus only on direct business written by
insurers without considering the effects of reinsurance. FIO recognizes
that the availability of reinsurance affects the availability of
insurance for policyholders. Similarly, FIO recognizes that how
reinsurance is priced will affect how much policyholders will pay for
insurance and impacts insurers' financial results.
Estimate of Burden for Representative Sample Insurers
FIO estimates that the number of Representative Sample Insurers
required to provide information under this data collection will be
approximately 213. FIO also estimates that it will take each
Representative Sample Insurer between approximately 100 to 350 hours
total to provide all of the data that the proposed data collection
seeks for the five years (2017 to 2021).
The overall estimated annual burden would be between approximately
21,300 and 74,550 hours (213 Representative Sample Insurers x 100 hours
and 213 Representative Sample Insurers x 350 hours). At a blended,
fully loaded hourly rate of $54.27,\36\ the total cost for all
Representative Sample Insurers to comply with the proposed data
collection would be between approximately $1,155,951 and $4,045,829.
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\36\ Based on data from ``Insurance Carriers and Related
Activities: NAICS 524,'' U.S. Bureau of Labor Statistics, <a href="https://www.bls.gov/iag/tgs/iag524.htm">https://www.bls.gov/iag/tgs/iag524.htm</a>, the average wage rate for all
insurance employees was $40.47 in June 2022, and the total benefit
compensation in the 1st Quarter of 2022 was 34.1 percent, which is a
benefit multiplier of 1.341. Therefore, a fully-loaded wage rate for
insurance employees is $54.27, or $40.47 x 1.341.
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The majority of Representative Sample Insurers belong to insurance
groups. As a result, such insurers may experience synergies and
efficiencies when completing the Template. Thus, the total number of
hours that it may take all Representative Sample Insurers to collect,
process, and complete the Template may be less than the number of hours
that FIO has estimated here.
Efforts To Collect Data From Other Sources
The FIO Act requires FIO to coordinate with State Insurance
Regulators, relevant federal agencies, and publicly available sources
in accordance with procedures set forth in the Act before FIO seeks to
collect the data directly from insurers.\37\ FIO has
[[Page 64140]]
determined that the data it seeks is either not available or cannot be
obtained in a timely manner from State Insurance Regulators, relevant
federal agencies, or publicly available sources, and therefore proposes
to use its data collection authorities under the FIO Act.
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\37\ 31 U.S.C. 313(e)(4) provides that ``Before collecting any
data or information under paragraph (2) from an insurer, or
affiliate of an insurer, the Office shall coordinate with each
relevant Federal agency and State insurance regulator (or other
relevant Federal or State regulatory agency, if any, in the case of
an affiliate of an insurer) and any publicly available sources to
determine if the information to be collected is available from, and
may be obtained in a timely manner by, such Federal agency or State
insurance regulator, individually or collectively, other regulatory
agency, or publicly available sources. If the Director determines
that such data or information is available, and may be obtained in a
timely manner, from such an agency, regulator, regulatory agency, or
source, the Director shall obtain the data or information from such
agency, regulator, regulatory agency, or source. If the Director
determines that such data or information is not so available, the
Director may collect such data or information from an insurer (or
affiliate) only if the Director complies with the requirements of
subchapter I of chapter 35 of title 44, United States Code (relating
to Federal information policy; commonly known as the Paperwork
Reduction Act), in collecting such data or information.
Notwithstanding any other provision of law, each such relevant
Federal agency and State insurance regulator or other Federal or
State regulatory agency is authorized to provide to the Office such
data or information.''
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On June 30, 2022, FIO began the coordination process with the
states with an email to each of the State Insurance Regulators in all
50 states, DC, and the U.S. territories. This email described the data
FIO would be seeking and requested from each State Insurance Regulator
a response as to whether the regulator would be able to provide all of
the requested data for any of the identified entities for all of the
ZIP Codes in which the entities operate within 30 days of being asked.
FIO continued its engagement and coordination over the next two months.
FIO received answers from 49 states, DC, and the five U.S. territories.
These jurisdictions indicated that they could not provide all of the
information described in the Template for any of entities identified
for every ZIP Code in which those entities operated. FIO had multiple
engagements with one state that did not directly answer the question
posed by FIO. This state indicated that it could facilitate the
collection of the data but did not indicate that it currently had the
data to provide to FIO. FIO has determined that the requested data from
this state cannot be obtained in a timely manner upon request by FIO.
Based on the responses received from the State Insurance Regulators,
FIO has determined that the data described in the Template is either
not available or cannot be obtained in a timely manner from any of the
states, DC, or the five U.S. territories.
With regard to relevant federal agencies and publicly available
sources, FIO understands that no federal agency currently collects the
ZIP Code level data described in the Template for all of the relevant
entities. While some insurance policy level data is available from
statistical agents that aggregate data obtained by State Insurance
Regulators from insurance companies, such data is generally available
only after paying a significant fee. Additionally, while statistical
agents do collect some ZIP Code level data, that data is not uniformly
collected in every state. Moreover, this data is not collected in a
standardized format and, in some instances, lacks elements necessary
for FIO's analysis of climate-related risk. Therefore, FIO cannot
obtain comparable and sufficiently granular nationwide data for its
analysis through statistical agents.
Submission of Data
Entities classified as Representative Sample Insurers would submit
data using the provided Template. Such insurers would be expected to
submit the completed Template through a secure web portal provided by
FIO within a specified time period, such as 60 days. Treasury intends
to provide training and additional resources throughout the data
collection period to facilitate the proper completion of reporting
templates. Reporting under this data collection would be mandatory for
all Representative Sample Insurers.
Given the sensitivity of the requested data, Treasury expects to
provide appropriate levels of confidentiality to respondents. The FIO
Act requires FIO to maintain the privacy or confidentiality of
submissions of non-publicly available data and information to FIO.\38\
Under the FIO Act, submissions pursuant to this possible data
collection will not constitute a waiver of, or otherwise affect, any
privilege arising under federal or state law to which the data or
information is otherwise subject.\39\
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\38\ FIO Act, 31 U.S.C. 313(e)(5).
\39\ FIO Act, 31 U.S.C. 313(e)(5).
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All data collection is expected to be done through a secure portal
maintained by Treasury, and Treasury will not publish confidential
firm-specific data from individual submissions. FIO may publish
aggregated analyses of the submitted information.
Request for Comments
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
[[Page 64141]]
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.
Procedural Requirements
Paperwork Reduction Act. The collection of information contained in
this Request for Comments will be submitted to the Office of Management
and Budget (OMB) for review as a revision to OMB Control Number 1505-
NEW under the requirements of the Paperwork Reduction Act, 44 U.S.C.
3507(d). Comments should be sent to Treasury in the form discussed in
the ADDRESSES section of this Request for Comments. Comments on the
collection of information should be received within December 20, 2022.
Comments are being sought with respect to the collection of
information in the proposed FIO climate-related data collection.
Treasury specifically invites comments on: (a) whether the proposed
collection of information is necessary for the proper performance of
the functions of FIO, including whether the information shall have
practical utility; (b) ways to enhance the quality, utility, and
clarity of the information collection; (c) whether the burden estimate
is accurate; and (d) whether there are ways to minimize the burden,
including through the use of automated collection techniques or other
forms of information technology.
Dated: October 14, 2022.
Steven E. Seitz,
Director, Federal Insurance Office.
[FR Doc. 2022-22880 Filed 10-20-22; 8:45 am]
BILLING CODE 4810-AK-P
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</html>Indexed from Federal Register on October 21, 2022.
This is legal information, not legal advice. Laws vary by jurisdiction and change frequently. Always verify current law with official sources and consult a licensed attorney in your jurisdiction for advice on your specific situation.