75380 Federal Register / Vol. 88, No. 211 / Thursday, November 2, 2023 / Notices 

1Executive Order on Climate-Related Financial 

Risk, Exec. Order No. 14030, 86 FR 27,967 (May 20, 

2021) (E.O. 14030). 

2 31 U.S.C. 313(c); E.O. 14030. FIO addressed the 

first undertaking for FIO under E.O. 14030 with the 

publication of its report Insurance Supervision and 

Regulation of Climate-Related Risks (June 2023), 

https://home.treasury.gov/system/files/311/FIOJune-2023-Insurance-Supervision-and-Regulationof-Climate-Related-Risks.pdf. 

3 31 U.S.C. 313–314. 

4 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.’’ 

5Agency Information Collection Activities; 

Proposed Collection, Comment Request; Federal 

Insurance Office Climate-Related Financial Risk 

Data Collection, 87 FR 64,134 (October 21, 2022) 

(October 2022 FRN). 

6October 2022 FRN, 87 FR at 64,140. 

Correspondence and Contact 

Information. 

[FR Doc. 2023–24222 Filed 11–1–23; 8:45 am] 

BILLING CODE 4810–AK–P 

DEPARTMENT OF THE TREASURY 

Agency Information Collection 

Activities; Submission for OMB 

Review; Comment Request; Federal 

Insurance Office Climate-Related 

Financial Risk Data Collection for U.S. 

Homeowners Multi-Peril Underwriting 

Data 

AGENCY: Federal Insurance Office, 

Departmental Offices, Department of the 

Treasury. 

ACTION: Notice of information collection; 

request for comment. 

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 will 

submit the following information 

collection request to the Office of 

Management and Budget (OMB) for 

review and clearance in accordance 

with the Paperwork Reduction Act of 

1995 (PRA), on or after the date of 

publication of this notice. This data 

collection will assist FIO’s assessment 

of the potential for any major 

disruptions of private insurance 

coverage in regions of the country 

particularly vulnerable to climate 

change impacts. The public is invited to 

submit comments on this request. 

DATES: Comments must be received by 

December 4, 2023 to be assured of 

consideration. 

ADDRESSES: Written comments and 

recommendations for the proposed 

information collection should be 

submitted at https://www.reginfo.gov/ 

public/do/PRAMain. Find this 

information collection by selecting 

‘‘Currently under 30-day Review—Open 

for Public Comments’’ or by using the 

search function. 

FOR FURTHER INFORMATION CONTACT: 

Copies of the submissions may be 

obtained from Elizabeth Brown, Senior 

Insurance Regulatory Policy Analyst, by 

emailing Elizabeth.Brown@treasury.gov, 

calling (202) 597–2869, or viewing the 

entire information collection request at 

www.reginfo.gov. 

SUPPLEMENTARY INFORMATION: 

Title: Federal Insurance Office 

Climate-Related Financial Risk Data 

Collection for U.S. Homeowners MultiPeril Underwriting Data. 

OMB Control Number: 1505–NEW. 

Type of Review: Request for a new 

OMB Control Number. 

Description: On May 20, 2021, 

President Biden issued the Executive 

Order on Climate-Related Financial 

Risk, Exec. Order No. 14030 (E.O. 

14030), which called on FIO to: (1) 

‘‘assess climate-related issues or gaps in 

the supervision and regulation of 

insurers’’ and (2) ‘‘further 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.’’ 1 This 

information collection is necessary for 

FIO to advance its statutory mandates 

(including to monitor the extent to 

which traditionally underserved 

communities and consumers, 

minorities, and low- and moderateincome persons have access to 

affordable insurance products, and to 

monitor all aspects of the insurance 

industry) and to fulfill the second 

undertaking for FIO under E.O. 14030.2

Under FIO’s data collection, FIO will 

obtain consistent, granular, and 

comparable homeowners insurance data 

that is not otherwise publicly available 

on a nationwide level. This nationwide 

view is critical to understanding how 

climate-related financial risks impact 

families and individuals across state 

markets and the United States, and how 

these effects could impact the broader 

financial system. 

FIO Authorities 

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; monitoring 

the extent to which traditionally 

underserved communities and 

consumers, minorities, and low- and 

moderate-income persons have access to 

affordable insurance products; 

collecting data and information on and 

from the insurance industry and 

insurers; analyzing and disseminating 

data and information; and issuing 

reports regarding all lines of insurance 

that FIO monitors.3 Each of these 

authorities is relevant to FIO’s planned 

data collection. 

Efforts To Collect Data From Other 

Sources 

Before FIO seeks to collect data 

directly from insurers, the FIO Act 

requires FIO to coordinate with relevant 

insurance regulators in the 50 states, the 

District of Columbia, and the five U.S. 

territories (collectively, the State 

Insurance Regulators), relevant federal 

agencies, and any publicly available 

sources in accordance with procedures 

set forth in the FIO Act before FIO 

collects the data directly from insurers.4

Prior to publishing FIO’s October 2022 

notice and request for comment related 

to the proposed data collection (October 

2022 FRN), FIO coordinated with State 

Insurance Regulators to determine if 

they could provide in a timely manner 

the data that FIO proposed collecting.5

Following those efforts, as described in 

detail in the October 2022 FRN, FIO 

determined that the data that FIO was 

proposing to collect was not available or 

could not be obtained in a timely 

manner from any of the State Insurance 

Regulators, relevant federal agencies, or 

publicly available sources.6

After the end of the comment period 

for the October 2022 FRN, FIO had 

additional meetings with the NAIC and 

the State Insurance Regulators to offer 

increased coordination and 

collaboration between FIO’s proposed 

data collection and any efforts of the 

NAIC and State Insurance Regulators. 

On August 15, 2023, the NAIC 


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7NAIC, ‘‘NAIC to Issue Data Call to Help 

Regulators Better Understand Property Markets,’’ 

news release, August 15, 2023, https://

content.naic.org/article/naic-issue-data-call-helpregulators-better-understand-property-markets. 

8 31 U.S.C. 313(e). 

9See, e.g., Christopher Flavelle, et al.‘‘Climate 

Shocks Are Making Parts of America Uninsurable. 

It Just Got Worse,’’New York Times May 31, 2023, 

https://www.nytimes.com/2023/05/31/climate/ 

climate-change-insurance-wildfires-california.html. 

10U.S. Department of the Treasury, The Impact of 

Climate Change on American Household Finances 

(September 2023), 12, https://home.treasury.gov/ 

system/files/136/ 

Climate_Change_Household_Finances.pdf. 

11See, e.g., White House Council of Economic 

Advisors, Economic Report of the President (March 

2023), Box 9–2, 281, https://whitehouse.gov/wpcontent/uploads/2023/03/ERP-2023.pdf; U.S. 

Department of the Treasury, The Impact of Climate 

Change on American Household Finances, 6. 

12 Insurance Information Institute, Homeowners 

Perception of Weather Risks: 2023 Q2 Consumer 

Survey (2023), 2, https://www.iii.org/sites/default/ 

files/docs/pdf/2023_q2_ho_perception_

of_weather_risks.pdf. 

announced a plan to issue a data call to 

assist State Insurance Regulators to 

collect data from insurers to better 

understand property markets and 

coverages and protection gaps, citing the 

‘‘increasing frequency and severity of 

weather events, rising reinsurance costs, 

and inflationary pressures’’ that were 

creating insurance availability and 

affordability issues.7 FIO supports 

continued coordination and 

collaboration efforts that would enable 

it to fulfill its statutory mission while 

minimizing any burdens on insurers, to 

the extent feasible. It is unclear when 

the NAIC data call may be implemented 

and whether all State Insurance 

Regulators will participate in any 

proposed NAIC data call. FIO will 

continue to engage with the NAIC and 

monitor its development of a 

homeowners insurance data collection 

template and the use of that template or 

similar templates by State Insurance 

Regulators. 

In sum, FIO has determined that the 

nationwide ZIP Code level data that it 

seeks to collect is not available or may 

not be obtained in a timely manner and 

has therefore determined to use its datacollection authorities under the FIO Act 

to obtain the necessary data directly 

from certain insurance groups.8

Importance of Data Collection 

The proposed data collection would 

provide FIO with a nationwide view of 

homeowners insurance that is critical to 

understanding how climate-related 

financial risks impact families and 

individuals across the United States and 

how these effects could impact the 

broader financial system. Since the 

publication of the October 2022 FRN, 

multiple homeowners insurers have 

announced decisions to exit certain 

areas or to decline to renew certain 

policies.9 As Treasury stated in a recent 

report: ‘‘Some evidence shows that 

states with exposure to climate hazards 

are already experiencing higher 

insurance costs, and the availability of 

insurance could have differential 

impacts for mortgage availability.’’ 10

Price increases often disproportionately 

impact traditionally underserved and 

disadvantaged communities and 

consumers, including those who are 

low- and moderate-income.11 Price 

increases could make insurance 

unavailable for such groups because 

they may be priced out of the market. 

A recent survey showed that about half 

of U.S. homeowners who did not 

purchase homeowners insurance had 

household incomes under $40,000 per 

year.12 FIO’s work will facilitate further 

research and analysis to better 

understand the effects of climate-related 

risks on housing and the resulting 

ramifications for household finances 

and homeowners. 

Purpose of Data Collection 

FIO plans to use the information 

obtained from this data collection to 

perform a nationwide analysis to 

advance its statutory mandates and to 

respond to E.O. 14030. FIO will assess 

the impact of climate-related risk on the 

availability and cost of homeowners 

insurance in the United States. The 

primary goal of this data collection is to 

obtain consistent, comparable, and 

granular homeowners insurance data 

that is not otherwise publicly available 

that will enable FIO to assess the impact 

that climate-related physical risks have 

had on the homeowners insurance 

market since 2017 at a ZIP Code level. 

Data of the type FIO seeks is, at present, 

generally available only at the national 

or state level, with limited data 

available at a more granular level. Using 

the data from this collection, FIO will 

analyze nationwide trends, including 

comparisons of trends in homeowners 

insurance availability and costs. This 

data collection and analysis will benefit 

a wide variety of stakeholders, 

including insurers, reinsurers, 

homeowners, mortgage lenders, and 

policyholders, and inform policymakers 

by establishing a framework for 

granular, consistent, and comparable 

data with which to assess the localized 

impact of climate-related events and 

conditions on trends in homeowners 

insurance availability and cost. This 

data will help highlight underwriting 

trends and help identify areas where 

less-available or more-costly insurance 

is associated with higher risks from 

climate-related events. Such 

information may also help inform 

private and public efforts at the federal, 

state, and local levels to target predisaster mitigation measures and to 

improve policy in this area. 

The narrower focus of this data 

collection includes data that will help 

establish a national baseline for 

analytics in this area. There is also 

potential value in collecting and 

analyzing more detailed information in 

this area. FIO intends to conduct 

climate-related data collections and 

analyses in the future, with a goal of 

doing so on an annual basis. In its initial 

analysis, FIO will focus on 

understanding nationwide trends in 

underwriting data. In future data 

collections, FIO may analyze in more 

detail, among other things, climaterelated impacts on traditionally 

underserved communities or 

consumers, minorities, and/or low- and 

moderate-income persons. 

FIO will not publish data or analysis 

of specific companies or groups or 

comparisons of results across companies 

or groups. FIO also will not publish data 

on or analysis of the solvency of 

insurance companies or groups based on 

the data collected. When FIO publishes 

analyses based on the data it collects, 

such analyses will be based on grouplevel submissions that will be 

aggregated across insurance groups to 

the ZIP Code level. 

Data Collection’s Key Elements 

The October 2022 FRN provided the 

rationale for the proposed data 

collection and its eight key elements: (1) 

a focus on insurer underwriting, (2) 

insurance lines of business, (3) insurers, 

(4) data fields, (5) reporting framework, 

(6) reporting period, (7) geographic 

granularity, and (8) geographic scope. 

Figure 1 below describes the initial 

proposed scope as well as FIO’s changes 

to narrow that scope based in large part 

on stakeholder feedback. Among other 

things, FIO is removing data fields for 

which information is substantially 

similar to other fields, cannot be 

collected consistently at this time, or is 

not necessary for FIO’s initial analysis. 

FIO believes that the narrower focus of 

this collection will improve data 

consistency and homogeneity and 

reduce the burden on the responding 

insurers. 


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75382 Federal Register / Vol. 88, No. 211 / Thursday, November 2, 2023 / Notices 

13Liability risk is ‘‘a risk where an insured is 

liable to a third party as a result of or caused by 

any act, error, omission representation or statement 

by the insured.’’ ‘‘Liability Risk Definition,’’ Law 

Insider, https://lawinsider.com/dictionary/liabilityrisk. 

14HO–3 policies comprise 55.5 percent of all 

homeowners insurance policies and 78.3 percent of 

all owner-occupied homeowners insurance policies. 

See NAIC, Dwelling Fire, Homeowners OwnerOccupied, and Homeowners Tenant and 

Condominimum/Coorperative Unit Owner’s 

Insurance Report: Data for 2020 (December 2022), 

4, https://naic.soutronglobal.net/Portal/Public/enGB/DownloadImageFile.ashx?objectID=9803&owner

Type=0&ownerId=2006. 

15For more details on the data fields, a copy of 

the Data Collection Form and the instructions for 

filling it out can be found on FIO’s webpage, 

https://home.treasury.gov/policy-issues/financialmarkets-financial-institutions-and-fiscal-service/ 

federal-insurance-office/reports-notices. 

FIGURE 1—CHANGES TO FIO’S DATA COLLECTION

Key elements Proposed scope in October 2022 FRN Summary of changes 

Underwriting 

Focus.

Physical risk from underwriting by P&C insurers, excluding liability 

risk 13.

No changes. 

Insurance Lines of 

Business.

Homeowners Multi-Peril with 6 form types covering Mobile Homeowners, Owner Occupied Homeowners, and Other Homeowners policy form types.Homeowners Multi-Peril with 1 form type covering Owner Occupied 

Homeowners (form type HO–3, the most common homeowners policy form). 

Insurers ............... Nationwide insurers writing above a premium threshold of $100 million 

in 2021 homeowners insurance direct premiums written.

Additional insurers in order to achieve at least an 80 percent market 

share threshold in each of 10 states that are potentially the most 

prone to climate-related disasters.

Top nationwide homeowners insurance groups with 1 percent or more 

share of the homeowners insurance market based on direct premiums written in 2022, and request data to be aggregated and submitted at an insurance group level for all homeowners insurance entities identified within the group. FIO has identified 14 homeowners 

insurance groups with 240 homeowners insurance entities meeting 

the selection criterion. 

Data Fields .......... 15 data fields covering 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 

policy information not collected on statutory filings.

7 data fields (removing 8 data fields from proposed collection for which 

information is substantially similar to other fields, cannot be collected 

consistently at this time, or is not necessary for the proposed initial 

analysis). 

Revise 1 data field for clarity (to collect number of policies not renewed 

or retained rather than premiums not renewed). 

Remove exclusion of non-weather-related damages from reporting on 

claims and losses. 

Reporting Framework.Accident year reporting basis ................................................................... Accident year reporting basis for loss- and claims-related data, and calendar year reporting basis for premium-related data and policy information. (This change provides clarity on alignment with the format of 

statutory filings). 

Reporting Period 5 years of underwriting data (2017–2021) ............................................... 6 years of underwriting data (2017–2022). 

Geographic Granularity.ZIP Code level for all U.S. ZIP Codes applicable to in-scope insurers ... No changes. 

Geographic 

Scope.

Nationwide ................................................................................................ No changes. 

Underwriting Focus and Line of 

Business 

FIO’s data collection remains focused 

on the physical risk from underwriting 

by property & casualty insurers. The 

data collection also remains focused on 

the homeowners insurers multi-peril 

line of business. However, in large part 

in response to comments, this data 

collection will seek data relating to 

policies on a single form type (rather 

than the six forms proposed in the 

October 2022 FRN). Specifically, FIO 

will focus on owner-occupied 

homeowners multi-peril insurance 

policies issued on form ‘‘HO–3,’’ the 

most common homeowners insurance 

policy form in the United States.14

Insurers 

For this initial data collection, FIO 

plans to collect data from the top 

homeowners insurance groups that have 

1 percent or more of the U.S. 

homeowners insurance market as 

measured by aggregate homeowners 

insurance direct premiums written in 

2022. FIO has identified 14 homeowners 

insurance groups that meet this criterion 

(the Representative Sample Insurers). 

FIO’s selection includes one standalone 

entity which is not part of a group. FIO’s 

references to ‘‘group’’ include this 

standalone entity. These 14 groups (out 

of the 195 homeowners insurance 

groups operating in the United States) 

collectively underwrite about 70 percent 

of the direct homeowners insurance 

premiums written in the 50 states, the 

District of Columbia, and U.S. 

territories, based on 2022 financial 

statements. The Representative Sample 

Insurers have 240 homeowners 

insurance entities domiciled in 29 states 

and operating in many other states 

nationwide. FIO is taking a 

representative sample approach for two 

reasons: (1) FIO anticipates, for the 

purposes of its analyses, that the 

Representative Sample Insurers 

collectively have a sufficient market 

share for analyzing impacts in the U.S. 

market, and (2) the focus on the largest 

insurance groups will reduce the burden 

on small insurers. 

Data Fields 

FIO plans to collect data from the 

Representative Sample Insurers using 

the FIO Climate Data Collection: U.S. 

Homeowners Multi-Peril Form 2023–1 

(Data Collection Form), which is an 

Excel spreadsheet that FIO will provide 

to them.15 In the October 2022 FRN, FIO 

proposed collecting 15 data fields. 

Based in large part on the comments 

that FIO received, FIO has decided to 

collect only seven data fields: (1) 

Number of Policy In-Force Exposures 

(on a calendar year basis (CY)); (2) Total 

Dollar Value of Coverage for Dwelling, 

Other Structures, Personal Property, and 

Loss of Use (CY); (3) Number of Policies 

Not Renewed or Retained (CY); (4) 

Direct Premiums Written (CY); (5) Total 

Direct Losses Paid (on an accident year 

basis (AY)); (6) Total Direct Incurred 

Losses (AY); and (7) Cumulative 

Number of Claims Closed With Loss 

Payment (direct claims on AY). Data 

from all seven fields is necessary for FIO 

to advance its objectives described 

above. 

The Number of Policy In-Force 

Exposures field represents the count of 

policies that are in effect (i.e., in-force) 

as of December 31 for each reporting 

calendar year, where one policy in-force 

corresponds to one home covered in 

that year. (This field does not include 

policies that lapsed or were canceled 

during the year). The field is necessary 

for FIO to calculate several metrics on 

a per-policy basis to allow for 

comparison across ZIP Codes. For 

example, FIO will calculate the average 


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16See, e.g., NAIC, Dwelling Fire, Homeowners 

Owner-Occupied, and Homeowners Tenant and 

Condominium/Cooperative Unit Owner’s Insurance 

Report: Data for 2020 (2022), Table 3, 4, and 5, 

https://naic.soutronglobal.net/Portal/Public/en-GB/ 

DownoadImageFile.ashx?objectId=9803&

ownerId=2006; Massachusetts Division of 

Insurance, Annual Home Insurance Report for 

Calendar Year 2020, 11, https://www.mass.gov/doc/ 

the-2020-massachusetts-market-for-homeinsurance/download. 

17See California Department of Insurance, ‘‘FACT 

SHEET: Data on Insurance Non-Renewals and FAIR 

Plan,’’ news release, December 20, 2021, https:// 

www.insurance.ca.gov/0400-news/0100-pressreleases/2021/upload/nr117DataNonRenewalsandFAIRPlan12202021.pdf; NAIC, 

Property & Casualty Market Conduct Annual 

Statement Homeowner Data Call & Definitions, 

https://content.naic.org/sites/default/files/inlinefiles/industry_mcas_data_call_def_

homeowners_2020.pdf. While the ‘‘Number of 

Policies Not Renewed or Retained’’ is not an annual 

statutory filing field, the NAIC collects statewide 

information on ‘‘Number of Company-Initiated nonrenewals during the period,’’ ‘‘Number of 

cancellations for non-pay or non-sufficient funds,’’ 

and ‘‘Number of cancellations at the insured’s 

request’’ from insurers writing homeowners policies 

as part of its Market Conduct Annual Statement 

data call, and these fields collectively sum to the 

number of policies not renewed or retained. 

18 LexisNexis Risk Solutions, ‘‘Annual U.S. Home 

Insurance Trends Report Confirms Upward Trend 

in Loss Cost and Severity across All Perils,’’ news 

release, October 13, 2022, https://

risk.lexisnexis.com/about-us/press-room/pressrelease/20221013-home-insurance-trends-report; 

Pat Howard & Kara McGinley,’’ Homeowners 

Insurance Claims Statistics in 2023,’’ Policygenius, 

December 22, 2022, https://www.policygenius.com/ 

homeowners-insurance/homeowners-insurancestatistics/. 

19AM Best, Best’s Guide to Understanding the 

Insurance Industry (2023), 6, https://

web.ambest.com/information-services/salesinformation/best-s-guide-to-understanding-theinsurance-industry. 

20 See Martin Grace & Robert Klein, 

‘‘Homeowners Insurance: ‘‘Markets Trends, Issues 

and Problems,’’ SSRN Electronic Journal, August 

2003, https://www.researchgate.net/publication/ 

228227047_Homeowners_Insurance_Market_

Trends_Issues_and_Problems. 

premiums, claims, losses, and policy 

non-renewals based on the total policies 

in a given ZIP Code; this field will also 

support calculation of changes in total 

policy counts over time. 

The Total Dollar Value of Coverage 

for Dwelling, Other Structures, Personal 

Property, and Loss of Use field 

represents the total estimated value of 

insurance coverage for the dwellings or 

other property covered by the policies 

(i.e., the potential exposures) in a ZIP 

Code, as recorded at the effective date 

of the policies or the date of their most 

recent renewal. This field is necessary 

because the premiums charged for 

policies will vary with the value of the 

properties insured as well as other 

factors. The dollar value of coverage and 

various calculated fields derived from 

that (e.g., average premium per $1,000 

in coverage) are commonly relied upon 

as metrics for accessing cost of 

coverage.16 The field will help FIO, 

among other things, assess the variation 

in the amount of financial protection for 

properties across ZIP Codes and over 

time for a given premium, while holding 

constant changes in insurance coverage. 

The field will also enable FIO to 

compare losses across ZIP Codes by 

calculating losses per $1,000 of 

insurance coverage. 

The Number of Policies Not Renewed 

or Retained field addresses the number 

of policies that are not renewed or 

retained at any time during the 

reporting year, including non-renewals 

that are either insurer-initiated or 

policyholder-initiated. This field is 

necessary because understanding the 

percentage of policies not renewed will 

help FIO to assess availability issues. 

FIO notes that non-renewals alone may 

not be an adequate representation of 

availability issues because policies 

could be discontinued by the 

policyholder for various reasons, such 

as homeownership changes or switching 

to insurers that are not Representative 

Sample Insurers. 

This field is replacing the field 

proposed in the October 2022 FRN that 

asked for the ‘‘Amount of Direct 

Premiums Written Renewed or 

Retained.’’ FIO is making this change 

because it is a more commonly reported 

measure of non-renewals. Some states 

(e.g., California) and the NAIC’s Market 

Conduct Annual Statement require 

insurers to report the number of policies 

not renewed or retained. 17 To the best 

of FIO’s knowledge, no state currently 

requires insurers to report ‘‘Amount of 

Direct Premiums Written Renewed or 

Retained.’’ Also, the ‘‘Number of 

Policies Not Renewed or Retained’’ is a 

subset of the data field that asks for the 

‘‘Number of Policy in-force Exposures,’’ 

because in order to provide the 

‘‘Number of Policy in-force Exposures,’’ 

an insurer would need to know both (1) 

the number of policies that it renewed 

or retained and (2) the number of 

policies not renewed or retained (i.e., 

the information FIO is requesting). 

FIO is retaining a data field for nonrenewals because many commenters 

noted the importance of collecting 

information on non-renewals in order to 

understand where insurers may be 

pulling back coverage. Monitoring the 

number of non-renewals will allow FIO 

to understand non-renewal rates as 

distinct from changes in premiums. 

The Direct Premiums Written field is 

a measure of policyholders’ cost of 

obtaining coverage, and is necessary 

because the average premium per home 

or per $1,000 of coverage (premiums 

divided by number of policies or 

premiums divided by the amount of 

coverage) indicates what homeowners 

pay for property insurance on a 

comparable per-unit basis. That 

information, in turn, is necessary 

because changes in premiums over time 

and comparisons of average premium 

per home on a nationwide basis can 

provide meaningful insights into 

insurance costs. Collecting this data on 

a calendar year basis will provide FIO 

with up-to-date information on pricing 

trends. Premium data can also support 

analysis of the availability of 

homeowners insurance in ZIP codes. 

The Total Direct Losses Paid field is 

necessary to understand how loss trends 

in each ZIP Code affect the availability 

and cost of homeowners insurance. 

Direct losses paid is the amount of 

money to date (for each accident year) 

that has been paid to, or on behalf of, 

policyholders, and does not include 

estimates of losses that have been 

incurred but not yet paid. FIO will 

analyze trends in paid losses (including 

on a per claim basis) by ZIP Code. FIO 

will also use this field to examine trends 

by ZIP Code in paid loss ratios (by 

dividing by premiums) and claims 

severity (by dividing by claims closed 

with loss payment) to better understand 

how underwriting metrics may reflect 

weather-related events. 

The Total Direct Incurred Losses field 

is necessary because it provides a 

comprehensive measure of the value of 

an insurer’s loss experience in a 

reporting period by ZIP Code. Unlike 

losses paid, incurred losses reflect the 

total value of losses that an insurer 

incurs during a given period, regardless 

of whether the losses have been paid out 

(i.e., it includes reserves), and is used to 

estimate total losses for a given year. 

FIO will analyze trends in incurred 

losses (including on a per-claim basis) 

by ZIP Code. FIO also will use this field 

to look at trends by ZIP Code in 

incurred-loss ratios (by dividing by 

premiums) to better understand how 

underwriting metrics may reflect 

weather-related events. 

The Cumulative Number of Claims 

Closed With Loss Payment field is 

necessary because the average amount 

insurers pay for each claim will provide 

insight on the impact of an event (or 

events) in a given area, helping FIO to 

identify exposure frequency and 

severity.18 During the underwriting 

process, an insurer must gauge the 

average value it will pay out per 

claim.19 Historically, the average cost of 

claims has been one of the primary 

factors behind the price increases and 

the tightened availability of 

homeowners insurance.20 FIO will be 


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75384 Federal Register / Vol. 88, No. 211 / Thursday, November 2, 2023 / Notices 

21 Insurance information may be reported on 

either a calendar year or an accident year basis, 

depending on the type of information being 

reported. Accident year reporting monitors loss 

development of a claim over time (and typically 

includes losses when they occur, not when they are 

reported). For example, if a hurricane occurs in 

2017, then 2017 would be the accident year. Losses 

and claims associated with the hurricane could 

occur in 2017 but could also develop into 

subsequent years as policyholders submit claims 

and receive payments over time but would be 

reported for the 2017 accident year. On the other 

hand, calendar year reporting does not change or 

develop over time beyond the calendar year. For 

example, premiums based on a 2017 calendar year 

would include premiums from January 1 to 

December 31, 2017. 22 See, e.g., October 2022 FRN, 87 FR at 64,138. 

evaluating claims frequency and 

severity on a nationwide basis to see if 

they are associated with average 

premiums growth or a decrease in the 

availability of homeowners insurance. 

This data field will thus enable FIO to 

better understand how underwriting 

metrics may reflect weather-related 

events. 

The seven data fields described above 

include three data fields not collected 

by State Insurance Regulators (the 

number of policy in-force exposures; the 

number of policies not renewed or 

retained; and the total dollar value of 

coverage for dwelling, other structures, 

personal property, and loss of use). The 

seven data fields also include four fields 

to collect ZIP Code level information 

nationwide regarding premiums, claims, 

and losses that correspond to four statelevel data fields reported by U.S. 

insurers to State Insurance Regulators in 

annual filings. 

Reporting Framework 

The Data Collection Form and 

accompanying instructions now clarify 

that Representative Sample Insurers 

should use accident year reporting basis 

for loss- and claims-related data and 

calendar year reporting basis for 

premium-related data and policy 

information.21 This change to the 

instructions provides clarity on 

alignment with the format of statutory 

filings; there is no fundamental change. 

Reporting Period 

FIO seeks to collect six years of 

underwriting data, 2017 through 2022 

(Reporting Period). This is a one-year 

expansion over the Reporting Period 

proposed in the October 2022 FRN. 

Expanding the reporting timeframe by 

one additional year will allow FIO to 

capture more current data, including the 

impact of recent climate-related 

disasters such as Hurricanes Ian and 

Nicole, and responds to stakeholder 

feedback recommending a longer 

Reporting Period. 

Geographic Scope and Granularity 

FIO will collect data at a ZIP Code 

level for all U.S. ZIP Codes in which the 

homeowners insurance entities within 

the Representative Sample Insurers have 

written owner-occupied multi-peril 

homeowners multi-peril policies 

corresponding to policy form HO–3 

during the Reporting Period in order to 

conduct a granular, nationwide 

assessment to advance its statutory 

mandates and respond to the second 

undertaking described in E.O. 14030. 

The October 2022 FRN outlines several 

reasons why ZIP Code level data is 

critical for FIO’s analysis, and those 

reasons remain valid.22

Collection Process 

Data will be collected from the 

Representative Sample Insurers on the 

Data Collection Form, which is a revised 

version of the template discussed in the 

October 2022 FRN. A copy of the Data 

Collection Form and the instructions for 

filling it out can be found at https://

home.treasury.gov/policy-issues/ 

financial-markets-financial-institutionsand-fiscal-service/federal-insuranceoffice/reports-notices. Each of the 

Representative Sample Insurers will be 

asked to aggregate and report the 

nationwide data requested by the Data 

Collection Form at a ZIP Code level for 

all owner-occupied homeowners multiperil policies corresponding to policy 

form HO–3 that the homeowners 

insurance entities within its group have 

written during the Reporting Period. 

Changes in Data Collection Based on 

Comments and Feedback Received 

In response to the October 2022 FRN, 

FIO received 35 formal written 

comments with over 9,400 signatories. 

Commenters included individuals, 

brokers, insurance industry trade 

associations, State Insurance Regulators, 

public interest groups, consumer 

advocates, climate and environmental 

groups, and others. Following the close 

of the comment period of the October 

2022 FRN, FIO met with a wide range 

of stakeholders, including the NAIC and 

some State Insurance Regulators, large 

writers of homeowners multi-peril 

insurance, and consumer and 

environmental groups, regarding the 

proposed data collection. In addition, 

FIO and members of the Federal 

Advisory Committee on Insurance 

(FACI) discussed the proposed data 

collection during two public FACI 

meetings and at meetings of the FACI 

Climate Subcommittee. 

Based on the public comments and 

stakeholder feedback, FIO has revised 

several aspects of its data collection, 

including the scope of the forms 

included in the homeowners insurance 

multi-peril line of business, the 

selection of insurers, the number of data 

fields, and the reporting period for the 

collection. FIO also revised the 

instructions for the Data Collection 

Form to clarify how the data should be 

reported, such as indicating that 

premium-related data and policy 

information should be provided on a 

calendar year basis and requiring all 

claims and losses to be reported, not just 

weather-related claims and losses. 

These changes, taken together, should 

lessen the burden on the insurers while 

also enhancing FIO’s analyses. 

Revised Focus Within Homeowners 

Line of Business 

FIO has revised its data collection to 

focus only on the owner-occupied 

homeowners multi-peril policy form 

known as HO–3. In response to the 

October 2022 FRN, insurers highlighted 

the difficulty of collecting consistent, 

comparable data across multiple policy 

form types. Limiting the collection to 

one form will allow FIO to collect more 

consistent, comparable data as 

compared to the proposal set forth in 

the October 2022 FRN, which proposed 

collecting six homeowners insurance 

policy forms. 

Revised Data Fields 

Based on the comments received and 

FIO’s decision to narrow the scope of 

the data collection, FIO removed eight 

of the fifteen data fields proposed in the 

October 2022 FRN. FIO removed fields 

for which the information is 

substantially similar to other fields (e.g., 

direct premiums earned), cannot be 

collected consistently at this time (e.g., 

total dollar amount of insurance 

deductible), or is not necessary for FIO’s 

initial analyses (e.g., number of claims 

reported). The narrower focus of this 

data collection includes data that will 

help establish a national baseline for 

analytics in this area. 

Revised Insurer Selection 

FIO did not receive many comments 

related to the proposed methodology for 

selecting the insurers for the proposed 

data collection, although it did receive 

comments on the overall burden of the 

proposed data collection, as well as on 

the potential use of the data for entityspecific analyses, and the operational 

burden of having groups report their 

subsidiaries on separate templates. In 

the October 2022 FRN, FIO’s proposed 

selection criteria for insurers were: (1) 

nationwide insurers writing above a 

premium threshold of $100 million in 


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Federal Register / Vol. 88, No. 211 / Thursday, November 2, 2023 / Notices 75385 

23Commenters that opposed ZIP Code level 

collection cited, among other things, the burden to 

insurers, the potential for misleading conclusions 

based on ZIP Code level claims data, and the 

possibility of exposing personally identifiable 

information or proprietary data in ZIP Codes with 

few policies. Those in favor of granular data 

collection tended to encourage FIO to collect data 

at an even finer granularity than ZIP Code, with 

census tract being the most common unit proposed. 

Those that preferred census tracts cited various 

rationales, including that they are comparable, have 

similar numbers of residents, tend to be internally 

similar, and align with census-defined geographies 

better than ZIP Codes. 

24 ‘‘Facts + Statistics: Homeowners and Renters 

Insurance,’’ Insurance Information Institute, https:// 

www.iii.org/fact-statistic/facts-statisticshomeowners-and-renters-insurance. 

25The Representative Sample Insurers encompass 

240 homeowners insurance entities, which is more 

than the 213 entities that would have been covered 

under the selection criteria outlined in the October 

2022 FRN. Any increase in burden from including 

more entities will be offset for two reasons. First, 

FIO is requesting that the 14 Representative Sample 

Insurers aggregate responses across all of their 

insurance entities, which should reduce the burden 

on any given entity and allow the groups to submit 

one consolidated response. Second, FIO is reducing 

the number of data fields and number of policy 

forms for which data should be collected, which 

will enable reduction of burden relative to the 

proposed estimate, even with the proposed change 

to add one more year of reporting. 

26FIO estimates that each individual homeowners 

insurance entity within a Representative Sample 

Insurer will take between 60 and 200 hours total to 

collect the requested data for six years (2017 to 

2022). The 14 Representative Sample Insurers have 

240 homeowners insurance entities (with the 

number of entities per group ranging from 1 to 44, 

so the burden for each Representative Sample 

Insurer would vary). The overall estimated burden 

hours are 14,400 (240 entities × 60 hours) to 48,000 

(240 entities × 200 hours). The average fully loaded 

hourly rate for insurance employees in July 2023 

was $58.30. Based on data from ‘‘Insurance Carriers 

and Related Activities: NAICS 524,’’ U.S. Bureau of 

Labor Statistics, https://www.bls.gov/iag/tgs/ 

iag524.htm, the average wage rate for all insurance 

employees was $43.31 in July 2023, and the total 

benefit compensation in the 2nd Quarter of 2023 

was 34.6 percent, which is a benefit multiplier of 

1.346. Therefore, a fully-loaded wage rate for 

insurance employees is $58.30, or $43.31 × 1.346. 

Thus, the total cost for all Representative Sample 

Insurers to comply with the data collection would 

be between approximately $839,520 (14,400 hours 

× $58.30/hour) and $2,798,400 (48,000 hours × 

$58.30/hour). 

27 Data on revenues for the 13 groups was derived 

from S&P Global Market Intelligence (S&P Global) 

on October 18, 2023. Data for the revenue of the 

standalone entity came from its annual statement 

for 2022. 

2021 homeowners insurance premiums; 

and (2) additional insurers in order to 

achieve at least an 80 percent market 

share threshold in each of 10 states that 

are potentially the most prone to 

climate-related disasters. 

Although FIO did not receive many 

specific comments on the selection of 

insurers, FIO is changing the selection 

criteria to cover only the largest 

homeowners insurance groups, i.e., 

those with 1 percent or more of the U.S. 

homeowners market nationwide, 

resulting in the selection of the top 14 

homeowners insurance groups by direct 

premiums written in 2022. FIO has 

revised the selection criteria in order to: 

(1) reduce the burden on smaller 

insurers; (2) alleviate concerns that FIO 

would be conducting entity-specific 

analyses; and (3) make the data 

operationally easier for insurers to 

report and for FIO to collect and 

analyze. 

Revised Reporting Period 

FIO is increasing the reporting period 

from the proposed five years (2017– 

2021) to six years (2017–2022) because 

expanding the reporting timeframe by 

one additional year will allow FIO to 

capture the impact of recent climaterelated disasters, including Hurricanes 

Ian and Nicole. A number of 

commenters supported a longer 

reporting period, although many of 

these called for adding multiple 

additional years. The overall burden for 

the Representative Sample Insurers will 

not increase, because FIO is removing 

eight of the fifteen data fields that it 

proposed in the October 2022 FRN and 

focusing on only one policy form (HO– 

3), instead of six policy forms. 

No Change to Geographic Scope or 

Granularity 

FIO received many comments on the 

proposal to collect data at the ZIP Code 

level, both for and against.23 FIO plans 

to move forward with ZIP Code level 

collection. As many commenters noted, 

state-level data would be insufficient for 

FIO’s analysis because climate-related 

risks and socioeconomic factors vary 

across geography, and state-level trends 

could differ from trends seen on a more 

granular level. While FIO understands 

the potential additional benefits of 

collecting census tract level data relative 

to ZIP Code information, FIO’s 

discussions with insurers and other 

stakeholders leads FIO to conclude that 

ZIP Code information tends to be 

collected by insurers as part of the 

address in a homeowners policy, while 

other geographic information, such as 

census tracts, may not be collected by 

insurers. Consequently, collecting data 

at a census tract level could increase the 

burden on insurers to produce 

information at that granularity. FIO 

believes that ZIP Code collection most 

appropriately balances the need for 

granular data with the responsibility to 

minimize collection burden. 

Revised Instructions 

FIO has revised the instructions for 

the Data Collection Form relating to the 

data fields. The proposed template 

instructions provided with the October 

2022 FRN directed insurers to report 

data only for losses and claims for 

weather-related damages. In discussions 

with FIO, however, insurers noted that 

it can be difficult or impossible to 

exclude non-weather-related damage 

from other loss estimates, based on how 

information is stored within insurers’ 

systems. In addition, information from 

the Insurance Information Institute 

shows that about 90 percent of 

homeowners insurance losses have been 

due to physical damage from wind, hail, 

water damage, freezing, fire, and 

lightning.24 Therefore, FIO has modified 

the instructions for the Data Collection 

Form to remove the exclusion of nonweather-related damages in connection 

with the reporting of claims and losses. 

Revised Burden Estimate 

FIO received many comments, 

including in follow-up stakeholder 

engagements, regarding its burden 

estimates, including the number of 

hours estimated (hour burden) and 

average salary used (hourly rate). 

Multiple comments stated that the hour 

burden estimate was too low and that 

the hourly rate should be higher to 

reflect the need for subject matter 

experts in actuarial and finance roles to 

respond to the collection. Other 

commenters supported FIO’s estimate 

and emphasized that the importance of 

the information collected outweighed 

the burden. 

FIO has revised its estimate of the 

hour burden to reflect that the data will 

be collected for: (1) only seven data 

fields, not the 15 data fields originally 

proposed; (2) only one policy form of 

homeowners insurance, not six as 

originally proposed; (3) one additional 

year, 2022, beyond the original 

proposed five years (2017–2021); and (4) 

the change in insurer selection 

criteria.25

FIO updated the estimated hourly rate 

to reflect the salary and benefit 

increases between June 2022 and July 

2023 reported by the U.S. Bureau of 

Labor Statistics. FIO has not, however, 

made any other adjustments to the 

hourly rate because the FIO data 

collection is largely an operational task 

focused on data already collected by 

insurers. 

FIO estimates the annual burden for 

its data collection is between 14,400 and 

48,000 hours at a total cost of $839,520 

to $2,798,400 for the Representative 

Sample Insurers, collectively.26 For 

reference, the Representative Sample 

Insurers reported aggregate revenues of 

over $372 billion in 2022.27 FIO’s 

revisions to its data collection have 

lowered the burden estimate by about 

30 per as compared to the estimates in 


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75386 Federal Register / Vol. 88, No. 211 / Thursday, November 2, 2023 / Notices 

28 31 U.S.C. 313(e)(5). 

29 31 U.S.C. 313(e)(5)(A). 

30 5 U.S.C. 552(b)(4). 

the October 2022 FRN (Figure 2). In 

addition, the Representative Sample 

Insurers are the 14 largest homeowners 

insurance groups and, as a result, they 

may experience internal synergies and 

efficiencies when completing the Data 

Collection Form. Thus, the total number 

of hours that it may take all 

Representative Sample Insurers to 

collect, process, and complete the Data 

Collection Form may be less than the 

number of hours that FIO has estimated 

here. 

FIGURE 2—COMPARISON OF BURDEN ESTIMATES

October 2022 

FRN 

Current 

estimates 

Hours per homeowners insurance entity ................................................................................................................. 100 to 350 60 to 200 

Total hours for all Representative Sample Insurers ................................................................................................ 21,300 to 

74,550 

14,400 to 

48,000 

Hourly rate ............................................................................................................................................................... $54.27 $58.30 

Total cost for all Representative Sample Insurers .................................................................................................. $1,155,951 to 

$4,045,829 

$839,520 to 

$2,798,400 

Analysis of Data Collected 

FIO currently plans to analyze the 

data collected using trend or time-series 

analysis. In the time-series analysis, FIO 

will assess trends in underwriting, 

claims, and loss metrics, normalized on 

a per-policy, premium, or coverage basis 

to allow for comparison across ZIP 

Codes, for owner-occupied homeowners 

multi-peril (HO–3 form) policies over 

the last six years. In addition to the data 

collected on the Data Collection Forms, 

FIO’s analysis will rely on several types 

of data that may include, but are not 

limited to, publicly available insurance 

information such as residual market 

information, information on the relative 

risks that locations face from climaterelated events, and data used to control 

for other changes in a ZIP Code that 

could influence insurance markets (e.g., 

inflation, real estate values, or changes 

in population). At a later stage, FIO may 

consider using additional 

methodologies, including multivariate 

statistical analysis. 

Submission of Data 

Reporting under this data collection 

would be mandatory for all 

Representative Sample Insurers. If OMB 

approves this data collection, the 

Representative Sample Insurers will be 

expected to submit the completed Data 

Collection Form through a secure 

Treasury web portal within 90 days of 

FIO publishing a Federal Register 

notice announcing the start of the data 

collection. (FIO has extended the time 

period which the Representative Sample 

Insurers will have to submit the 

information from 60 days to 90 days to 

ensure that they have sufficient time to 

gather and provide the requested data.) 

FIO intends to provide training and 

additional resources within the data 

collection period to facilitate the proper 

completion of reporting templates. 

Given the potential sensitivity of 

some of the requested data, FIO will 

seek to maintain the data submitted in 

a confidential manner. The FIO Act 

includes provisions addressing the 

privacy or confidentiality of 

submissions of non-publicly available 

data and information to FIO.28 In 

accordance with the FIO Act, 

submissions pursuant to this 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.29 FIO expects that 

data it receives under this collection 

will likely contain or consist of ‘‘trade 

secrets and commercial or financial 

information obtained from a person and 

privileged or confidential.’’ This type of 

information is subject to withholding 

under exemption 4 of the Freedom of 

Information Act.30

All data collection is expected to be 

completed through a secure portal 

maintained by Treasury, and FIO will 

not publish confidential firm-specific 

data from individual submissions. FIO 

may publish aggregated analyses of the 

submitted information. 

Form: FIO Climate Data Collection: 

U.S. Homeowners Multi-Peril Form 

2023–01. 

Affected Public: Businesses and other 

for-profit institutions and not-for-profit 

entities. 

Estimated Number of Respondents: 

14. 

Frequency of Response: On occasion, 

although FIO aims to conduct annual 

data collections. 

Estimated Total Number of Annual 

Responses: 14. 

Estimated Time per Response: Varies 

from 60 hours to 8,800 hours depending 

upon the number of homeowners 

insurance entities within a respondent 

group. The estimated total annual 

burden hours are 60 to 200 hours per 

homeowners insurance entity within a 

respondent group. The number of 

homeowners insurance entities within a 

respondent group varies from 1 to 44, 

with the average number being 17. 

Thus, the average estimated time per 

response ranges from 1,020 hours to 

3,420 hours. 

Estimated Total Annual Burden 

Hours: Approximately 14,400 to 48,000 

hours total for all respondents together. 

The estimated total annual number of 

burden hours for each respondent will 

be based on the number of homeowners 

insurance entities within each 

respondent group. The estimated total 

annual burden hours are 60 to 200 hours 

per homeowners insurance entity 

within a respondent group. 

Authority: 44 U.S.C. 3501 et seq. 

Spencer W. Clark, 

Treasury PRA Clearance Officer. 

[FR Doc. 2023–24248 Filed 11–1–23; 8:45 am] 

BILLING CODE 4810–AK–P 

UNIFIED CARRIER REGISTRATION 

PLAN 

Sunshine Act Meetings 

TIME AND DATE: November 7, 2023, 10 

a.m. to 1 p.m., mountain time. 

PLACE: This meeting shall take place at 

the Salt Lake City Marriott University 

Park, 480 Wakara Way, Salt Lake City, 

UT 84108. This meeting will also be 

accessible via conference call and via 

Zoom Meeting and Screenshare. Any 

interested person may call (i) 1–929– 

205–6099 (US Toll) or 1–669–900–6833 

(US Toll), Meeting ID: 999 1833 7574, to 

listen and participate in this meeting. 

The website to participate via Zoom 

Meeting and Screenshare is https://

kellen.zoom.us/meeting/register/ 

tJ0kduGrrTwvHdC_

v5GnxjaRGZbf1VnECKf2. 

STATUS: This meeting will be open to the 

public. 


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