Data is at the core of risk management, and the National Association of Insurance Commissioners (NAIC) is seeking to identify gaps in the data state regulators collect from insurers – particularly with respect to understanding insurance availability and affordability.
“The increasing frequency and severity of weather events, rising reinsurance costs, and inflationary pressures are making property insurance availability and affordability more challenging for a growing number of regions across the U.S.,” the NAIC said in a statement during its Summer National Meeting in August. “These dynamics can vary within a relatively small geographic area, so while a state’s property insurance market may be generally healthy overall, there can be localized protection gaps that challenge certain communities.”
The NAIC said states may lack the kind of data needed to gauge the availability and affordability of insurance for consumers. Under Alan McClain, Arkansas insurance commissioner and chair of the NAIC Property and Casualty Committee, insurance regulators of at least 30 states have started work to identify where data is lacking. The plan is to develop a data template to establish “a long-term, robust data collection strategy to help regulators more nimbly respond to inquiries related to their property markets versus a one-time data call.”
This approach contrasts with one proposed last year by the U.S. Treasury’s Federal Insurance Office (FIO). In its request for information (RFI), FIO proposed collecting data related to “insurers’ underwriting metrics and related insurance policy information.” It said the 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.”
Triple-I responded to the FIO RFI by saying, in part, that:
- The proposed call was duplicative and would ultimately hurt the people FIO wants to help;
- The ZIP Code-level data FIO said it was seeking could lead to misleading conclusions; and
- FIO could secure the information it needs from existing, publicly available data without placing an additional reporting burden on insurers.
Triple-I provided an extensive but not exhaustive list of resources for FIO to consider.
“There is no dearth of information to help FIO and policymakers address the conditions contributing to climate risk and drive the behavioral changes needed in the near, intermediate, and long term,” Triple-I wrote, reminding FIO that catastrophe-modeling firms prepare their industry exposure databases from public sources, not insurer data calls. “What is needed is to build on existing efforts and draw on the voluminous data and analysis already extant to target problem areas that are well understood.”
NAIC’s response to the RFI emphasized the importance of collaboration to address concerns about insurance availability and affordability and expressed displeasure at what it characterized as FIO’s “unilateral process.”
“While we recognize the Treasury’s desire to better understand the impact of climate risk and weather-related exposures on the availability and affordability of the homeowners’ insurance market,” NAIC wrote, “we are disappointed and concerned that Treasury chose not to engage insurance regulators in a credible exercise to identify data elements gathered by either the industry or the regulatory community.”
In a June 2023 report, FIO references the RFI and describes the proposed data call, stating that the comment period closed in December 2022 and that FIO is “assessing next steps.” The June report recognizes and commends the industry’s and the NAIC’s efforts to date but goes on to say that these efforts “are fragmented across states and limited in several critical ways.”
FIO makes 20 recommendations, and the report provides context for each, highlighting efforts already under way and explaining how implementation of the FIO recommendations could improve management and supervision of climate-related risks. It also proposes areas of focus for future work by state insurance regulators and the NAIC.