Letters to Regulators: Letter in Support of FIO’s Proposed Climate-Related Financial Risk Data Collection

View or download a PDF of the letter here.

AFREF led comments to the Federal Insurance Office in support of their proposed “Climate-Related Financial Risk Data Collection” from insurers. AFREF supports this data collection because the increasingly prevalent and severe weather hazards caused by climate change pose a massive threat to the housing stability, affordability, and safety of Americans nationwide. Purchasing insurance policies is one of the few actions individuals can take to protect their property from the effects of climate-driven natural disasters. Therefore, the cost and availability of insurance is deeply related to a household’s monthly housing costs and their ability to recover from damages following severe weather.

The letter encourages the FIO to expand data collection efforts beyond homeowners’ insurance to include additional types of insurance, claims delays and underpayment, policy cancellations, underinsurance, and renewal denials. Additionally, FIO should collect data annually at the census tract level, include additional information needed to establish economic or racial discrimination within census tracts, and share data and analysis with the public. FIO should also host field hearings across the country and roundtables with homeowners, renters, local government officials and community-based organizations, including housing counseling agencies to understand how climate-related insurance issues are presenting on the ground. Finally, FIO should make appropriate recommendations to state insurance regulators, federal banking regulators, the Federal Housing Finance Agency (FHFA), the Financial Stability Oversight Council (FSOC), and the Office of Financial Research (OFR).