FIO Requests Comments on a Proposed Data Call for Homeowners’ Insurance Underwriting Data to Aid in Assessment of Climate Risk

Granular Data Proposed to Be Collected from Over 200 P&C Insurers Intended to Aid FIO’s Assessment of Potential Impact of Climate-Related Risks on Availability and Affordability of Insurance Sullivan & Cromwell LLP - October 27, 2022
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On October 21, 2022, the U.S. Department of the Treasury’s Federal Insurance Office (“FIO”) published a notice and request for comment in the Federal Register that it proposes to collect certain underwriting data on homeowners’ insurance from approximately 213 property and casualty insurers for purposes of assisting FIO’s assessment of climate-related exposures and their potential effects on availability and affordability of insurance coverage. The level of granularity of the data proposed to be collected by FIO is at the ZIP Code level, and a total of five years of data (for Accident Years 2017 through 2021) are proposed to be collected—all of which may require insurers to undertake significant efforts to comply with the data call. FIO estimates that an insurer would need to expend between 100 and 350 hours total in order to comply with the data collection requirements as proposed. The proposed data collection is subject to a 60-day public comment period, which ends on December 20, 2022. Given the scope of information proposed to be collected, insurers should review how the data collection would affect them if adopted as proposed, and consider commenting on any aspects that would present particular challenges, either on an individual basis or through trade associations.