FACTA Credit-based Insurance Score Study – Homeowners Insurance #535987-00016

Submission Number:
535987-00016
Commenter:
Julie Gackenbach
Organization:
National Association of Mutual Insurance Companies
State:
DC
Initiative Name:
FACTA Credit-based Insurance Score Study – Homeowners Insurance

The National Association of Mutual Insurance Companies (“NAMIC”) is pleased to provide the attached comments to the Federal Trade Commission in response to the Commission’s May 19, 2008 request for public comment pertaining to the draft model order the Commission proposed to issue directing the use of compulsory process to obtain information for the homeowner’s insurance credit scoring study. Founded in 1895, NAMIC is the largest full-service national trade association serving the property-casualty insurance industry with more than 1,400 member companies in the United States. NAMIC members are small farm mutual companies, state and regional insurance companies, risk retention groups, national writers, reinsurance companies, and international insurance giants. NAMIC members underwrite over 40 percent of the homeowner’s insurance in the nation. The comments included in this transmission were compiled by Mike Miller, a noted actuary with particular expertise in both statistical analysis and database construction. His professional experience provides a unique perspective. NAMIC urges the FTC to reconsider the compulsory process now underway. Neil Alldredge Vice President, State & Regulatory Affairs