Triple-I recently was asked to comment on two measures now before the House Committee on Financial Services. H.R. 1756, an amendment to the Fair Credit Reporting Act, would prohibit use of credit information in underwriting or pricing auto insurance. H.R. 2684 would require the Treasury Department’s Federal Insurance Office (FIO) to annually study personal private auto insurance.
Our input is summarized below.
The insurance credit score is applied to create a rate appropriate to the customer’s riskiness. These scores help insurers avoid charging high-risk customers too little and low-risk customers too much. Every dollar of discount a person with a low score receives is offset by an extra dollar of surcharge to a person with a high score.
Introduced in the late 1980s, the scores have been studied numerous times and found to be a powerful predictor of the likelihood a consumer will become involved in an accident. Concerns have been raised that the scores act as a proxy for income – a variable insurers are banned from using. Recent research finds that this isn’t the case.
Most recently, in 2019 Triple-I and the Casualty Actuarial Society produced a white paper “Insurance Rating Variables: What They Are And Why They Matter” that explains how actuaries rigorously study variables for their effectiveness and impact on the societal goal of keeping insurance available and affordable.
Under H.R. 2684, it appears FIO would be required to annually gather premiums charged and quoted from insurers that write personal auto coverage, along with rating factors, underwriting guidelines, and any information used to compile them.
This would be an enormous undertaking. There are more than 250 million private vehicles in the United States – 87 percent of them insured. But the dataset would be much larger. The proposal also asks for every quote issued to policyholders and other applicants. Each renewal policy gets at least one quote – the renewal at existing terms. Anyone who shops for insurance receives more.
Once the information is collected, the bill would require the release of each insurer’s data, rating algorithms, and underwriting guidelines to the public – including the insurer’s competitors. This would be like requiring a drug manufacturer to give up all its patents annually. Insurers would have no incentive to innovate to find, for example, variables that do a better job than the current ones because, once discovered, the variables would have to be turned over to competitors.