December 20, 2022
Federal Insurance Office
Department of the Treasury
1500 Pennsylvania Ave NW
Washington, DC 20220
Re: Federal Insurance Office Climate-Related Financial Risk Data Collection
Dear Director Seitz,
Enclosed are 9,349 petition signatures in support of the Federal Insurance Office’s (FIO’s) proposed plan to collect data on the impact of climate change on insurance access and affordability. The signatories support the data collection, as well as the publication of as much data as FIO’s authorities allow and the publication of a detailed report with recommendations to protect access to affordable insurance.
Given the Federal Insurance Office’s mandate to monitor insurance access and affordability to traditionally underserved communities and consumers, Public Citizen and Americans for Financial Reform reached out to insurance consumers and other members of the public through an online petition to give them the opportunity to comment on the proposed data collection.
The petition garnered 9,349 signatures, along with 500 unique comments. Of the individuals who signed the petition, 3,567 are residents of the 10 states identified in the FIO proposal as potentially the most vulnerable to climate change. In a follow-up survey, 2,722 individuals identified themselves as insurance consumers. When asked whether their home or apartment had been affected by flooding, wildfires, or other extreme weather events in the last 5 years, 1 out of 5 (576) participants indicated that it had. 1 out of 3 (950) participants said they had noticed an insurance rate increase following a wildfire, flood, or other extreme weather event and that it had impacted their finances. Selected comments are highlighted below.
The full petition text reads as follows:
Thank you for proposing to collect data from insurance companies on how climate change is impacting access to affordable insurance. Access to insurance is essential for my and my community’s financial and emotional security. Insurers have had decades to prepare for climate change. Instead, they’ve contributed to it—and now they are passing the costs of wildfires, flooding, and other climate impacts on to our communities. If insurance becomes unaffordable or unavailable in my community, this crisis could threaten our homes, life savings, and local economies. My community needs urgent solutions to address this growing crisis.
Please collect all the data you need to understand how climate change affects insurance costs for all communities, and especially underserved communities. Low-income and minority communities already face the greatest risk from wildfires and flooding. Due to a legacy of racist practices, we need to know whether insurance companies are repeating past trends of charging these communities more while providing less in the aftermath of disasters. We know some insurers and state regulators are lobbying against this data collection. Don’t let them stop you from fulfilling your mission.
We hope you will publish a detailed report and as much data as your authorities allow to help researchers examine patterns and evaluate solutions. We also urge you to publish strong recommendations for regulators and Congress on how to protect access to affordable insurance, particularly for vulnerable and underserved communities.
We thank the Federal Insurance Office for taking this important step and urge it to strengthen and finalize the proposal on an expeditious timeline.
Americans for Financial Reform