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Letter to Federal Insurance Office on Release of Climate-Related Financial Risk Data

Federal Insurance Office Climate-Related Financial Risk Data Letter

December 13, 2024

Department of the Treasury
1500 Pennsylvania Ave NW
Washington, DC 20220

Re: Federal Insurance Office Climate-Related Financial Risk Data

Dear Secretary Yellen and Director Seitz,

On behalf of the undersigned consumer protection, climate, and housing justice organizations, we urge you to swiftly publish data and analysis from the property and casualty market intelligence data call on the impact of climate change on insurance affordability. As the costs of the climate crisis are mounting, rising insurance prices and retreating insurance companies is creating an affordability crisis that threatens Americans’ homes, life savings, and the economies of already vulnerable regions. Given the speed at which an insurance crisis is unfolding, comprehensive national data and analysis must be an urgent priority.

Communities across the country are already experiencing the impacts of rising insurance costs and withdrawal. Due to the disproportionate exposure to wildfires and flooding, low-income communities and communities of color are particularly at risk from insurance hikes and withdrawals. Yet the current absence of publicly available data on insurance premiums and claims impedes regulators, municipalities, researchers, and community organizations from monitoring trends, assessing economic impacts, providing analysis, and proposing solutions.

While the Federal Insurance Office (FIO) and the National Association of Insurance Commissioners have taken an important step by collecting data, public data and analysis are necessary to evaluate the full scale of the crisis and ensure all relevant actors can understand and act accordingly to mitigate the risk in their jurisdiction. The Federal Insurance Office was created specifically to fill a gap in the state-based regulation system by collecting and analyzing data. With a mandate to monitor the potential for systemic risks and impacts on marginalized communities, analysis from FIO is crucial to highlight emerging trends. We urge FIO to publish as much data in the most granular form that meets FIO’s statutory mandates and publish an initial analysis of data on property insurance.

Sincerely,

Public Citizen

Americans for Financial Reform Education Fund

Campax

Carrizo/Comecrudo Nation of Texas

Connecticut Citizen Action Group

Consumer Federation of America

Consumer Federation of California

Consumer Watchdog

CT Coalition for Economic and Environmental Justice

Emergency Legal Responders

Environmental Defense Fund

Extreme Weather Survivors

Fair Housing Center of Central Indiana

For a Better Bayou

Habitat Recovery Project

Little Tokyo Service Center

MA Affordable Homeownership Alliance

MARBE SA

Mothers Rise Up

National Association for Latino Community Asset Builders

National Coalition for Asian Pacific American Community Development

National Community Reinvestment Coalition

National Fair Housing Alliance

New York Communities for Change

Oil and Gas Action Network

Rebuild by Design

Revolving Door Project

Rise Economy

Sierra Club

The Center for NYC Neighborhoods, Inc.

Third Act

Third Act NYC

Turtle Island Restoration Network

Union of Concerned Scientists

Waterkeeper Alliance

Youth Climate Finance Alliance