1 

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, U.S. 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 30 DAYS AFTER DATE OF PUBLICATION IN 

THE FEDERAL REGISTER 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 Spencer W. Clark by e-mailing PRA@treasury.gov, calling (202) 927-5331, or viewing the 

entire information collection request at www.reginfo.gov. 

SUPPLEMENTARY INFORMATION: 

Federal Insurance Office (FIO), Departmental Offices, U.S. Department of the Treasury
2 

Title: Federal Insurance Office Climate-Related Financial Risk Data Collection for U.S. 

Homeowners Multi-Peril Underwriting Data 

OMB Control Number: 15XX-XXXX. 

Type of Review: New collection.

Description: On May 20, 2021, President Biden issued the Executive Order on Climate-Related 

Financial Risk, Exec. Order No. 14030 (EO 14030), which called on FIO to: (1) “assess climaterelated 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 

moderate-income 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 EO 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.

1 Executive Order on Climate-Related Financial Risk, Exec. Order No. 14030, 86 Fed. Reg. 27,967 (May 20, 2021)

(EO 14030).

2 31 U.S.C. 313(c); EO 14030. FIO addressed the first undertaking for FIO under EO 14030 with the publication of 

its report Insurance Supervision and Regulation of Climate-Related Risks (June 2023), 

https://home.treasury.gov/system/files/311/FIO-June-2023-Insurance-Supervision-and-Regulation-of-ClimateRelated-Risks.pdf. 
3 

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 moderateincome 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 

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.”
4 

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 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. 

5 Agency Information Collection Activities; Proposed Collection, Comment Request; Federal Insurance Office 

Climate-Related Financial Risk Data Collection, 87 Fed. Reg. 64,134 (October 21, 2022) (October 2022 FRN). 

6 October 2022 FRN, 87 Fed. Reg. at 64,140.

7 NAIC, “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-help-regulators-better-understand-property-markets. 
5 

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 data-collection 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 

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

9 See, 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-insurancewildfires-california.html. 

10 U.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. 

11 See, e.g., White House Council of Economic Advisors, Economic Report of the President (March 2023), Box 9-2, 

281, https://www.whitehouse.gov/wp-content/uploads/2023/03/ERP-2023.pdf; U.S. Department of the Treasury, 

The Impact of Climate Change on American Household Finances, 6. 
6 

$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 EO 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 lessavailable or more-costly insurance is associated with higher risks from climate-related events. 

12 Insurance Information Institute, Homeowners Perception of Weather Risks: 2023Q2 Consumer Survey (2023), 2, 

https://www.iii.org/sites/default/files/docs/pdf/2023_q2_ho_perception_of_weather_risks.pdf. 
7 

Such information may also help inform private and public efforts at the federal, state, and local 

levels to target pre-disaster 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, climate-related 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 group-level 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 
8 

narrower focus of this collection will improve data consistency and homogeneity and reduce the 

burden on the responding insurers.

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 risk13

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

13 Liability 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://www.lawinsider.com/dictionary/liability-risk. 
9 

 

 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 multiperil 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) 

14 HO-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 Owner-Occupied, and Homeowners 

Tenant and Condominium/Cooperative Unit Owner’s Insurance Report: Data for 2020 (December 2022), 4, 

https://naic.soutronglobal.net/Portal/Public/enGB/DownloadImageFile.ashx?objectId=9803&ownerType=0&ownerId=2006. 
10 

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 inforce 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 premiums, claims, losses, and policy non-renewals based on the total 

15 For 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/financial-markets-financial-institutions-and-fiscalservice/federal-insurance-office/reports-notices. 
11 

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

16 See, e.g., NAIC, Dwelling Fire, Homeowners Owner-Occupied, and Homeowners Tenant and 

Condominium/Cooperative Unit Owner’s Insurance Report: Data for 2020 (2022), Tables 3, 4, and 5, 

https://naic.soutronglobal.net/Portal/Public/enGB/DownloadImageFile.ashx?objectId=9803&ownerType=0&ownerId=2006; Massachusetts Division of Insurance, 

Annual Home Insurance Report for Calendar Year 2020, 11, https://www.mass.gov/doc/the-2020-massachusettsmarket-for-home-insurance/download. 
12 

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 inforce 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 non-renewals 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.

17 See 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/nr117DataNon-RenewalsandFAIRPlan12202021.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 CompanyInitiated non-renewals 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.
13

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 
14 

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 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 

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/pressroom/press-release/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-insurance-statistics/. 

19 AM Best, Best’s Guide to Understanding the Insurance Industry (2023), 6, https://web.ambest.com/informationservices/sales-information/best-s-guide-to-understanding-the-insurance-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_Proble

ms. 
15 

four state-level 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 multiperil 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 

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. 
16 

and respond to the second undertaking described in EO 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-institutions-and-fiscalservice/federal-insurance-office/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 multi-peril 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 

22 See, e.g., October 2022 FRN, 87 Fed. Reg. at 64,138.
17 

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 
18 

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 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 climaterelated 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 climate-related disasters, including Hurricanes Ian and 
19 

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 climaterelated 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 

23 Commenters 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.
20 

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 non-weather-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 

24 “Facts + Statistics: Homeowners and Renters Insurance,” Insurance Information Institute, https://www.iii.org/factstatistic/facts-statistics-homeowners-and-renters-insurance. 
21 

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 the October 2022 FRN (Figure 2). In 

addition, the Representative Sample Insurers are the 14 largest homeowners insurance groups 

25 The 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.

26 FIO 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 x 60 hours) to 48,000 (240 entities x 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 x $58.30/hour) and $2,798,400 (48,000 hours x 

$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. 
22 

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 

climate-related 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 
23

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.

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).
24

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