Treasury FIO and NAIC Homeowners Insurance Data Collection (updated)

UPDATED March 20, 2024: The Federal Advisory Committee on Insurance held a meeting today with Treasury Department officials, insurance industry representatives and state regulators. The discussion included decisions by Florida, Louisiana and Texas to opt-out of the NAIC data collection effort that is set to be shared with the Treasury Department's Federal Insurance Office (FIO). Steven E. Seitz, director of the FIO, declined to name or discuss the states that were not participating. A spokeswoman for the N.A.I.C. said the group did not plan to publish a list of participating states. If sufficient states opt out or share limited data with the NAIC, it is expected that the FIO may revert back to its plans to independently collect data from private insurers.

From March 8, 2024:

The U.S. Department of the Treasury’s Federal Insurance Office (FIO) has announced a collaboration with the National Association of Insurance Commissioners (NAIC) to collect data from the largest homeowners insurers, which FIO will then use to conduct a nationwide assessment of climate-related financial risks.

The FIO will now drop its previously stated intent - which the Office of Management and Budget had approved earlier this year - to directly request data from insurers, acknowledging industry concerns over the growing number of overlapping reporting burdens. The move seems to resolve a long-running dispute with state regulators, dating back to November 2022 when the NAIC wrote that the “FIO has failed to demonstrate a good faith effort to engage with state regulators and has exhibited their intention to forgo a collaborative effort to identify and collect accurate and useful data.”

The FIO is working towards meeting President Biden’s Executive Order on Climate-related Financial Risk, EO 14030 (May 20, 2021), which called on FIO to “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.” The FIO also has a broad statutory mandate to "monitor all aspects of the insurance industry," although state insurance regulators retain primary authority to regulate the industry.

“Americans across the country are seeing the affordability and availability of their insurance policies decline as a result of increasingly severe climate-related disasters,” said Secretary of the Treasury Janet L. Yellen. “I’m pleased that the Federal Insurance Office, state insurance regulators, and the NAIC are collaborating on this important data collection. Analysis of homeowners insurance data is essential to understanding the market impacts on consumers and helping policymakers across the country respond appropriately to the risks.”

The NAIC Property & Casualty Market Intelligence Data Call (PCMI) will gather data from more than 400 property insurers operating locally and across the country - representing over 80% of the market. Insurers are being asked to submit ZIP-code-level data across the U.S. on more than 70 data points including premiums, policies, claims, losses, limits, deductibles, non-renewals, and coverage types for the 5 year period from 2018 to 2022. To the extent permitted by applicable state law and per the agreements in place between states and the NAIC, data will be kept confidential.

“The PCMI data call represents the collaborative, nonpartisan work that state insurance regulators have undertaken through the NAIC to address the critical challenge of the affordability and availability of homeowners’ insurance and the financial health of insurance companies,” said NAIC President and Connecticut Insurance Commissioner Andrew N. Mais.

In announcing the data call, the NAIC went on to say that "rising property insurance costs and coverage challenges underscore the importance of this collective effort .... to provide deeper insights into property insurance market costs, coverages, and protection gaps amid the increasing frequency and severity of natural disasters, escalating reinsurance costs, and continued inflationary pressures."

All homeowners’ insurers subject to the data call were sent a letter dated March 8th, 2024 and will have 90 days (by June 6th, 2024) to submit their information.The NAIC and FIO have agreed that the NAIC will begin sending the data to FIO in June 2024, shortly after the close of the NAIC data collection. The NAIC has agreed to provide FIO with an anonymized subset of the data in late September

Details and reporting guidance from the NAIC are available here:

More information on the FIO's planned analysis is available through a Federal Register notice issued in November 2023 requesting public comment, available here:

Background on the FIO is available here:

Sources: U.S Treasury Department, https://home.treasury.gov/news/press-releases/jy2162 | NAIC, https://content.naic.org/article/states-issue-property-casualty-market-intelligence-data-call-covering-over-80-us-market