OPENING PARAGRAPHS: Letter Re: Consumer and Community Organizations’ Response to Federal Insurance Office Request for Information: Monitoring the Availability and Affordability of Auto Insurance: Assessing Potential Evolution of the Auto Insurance Market. Dear Mr. Hart: Texas Appleseed is a public interest justice center working to change unjust laws and policies that prevent Texans from realizing their full potential. Working with pro bono partners and collaborators, Texas Appleseed develops and advocates for innovative and practical solutions to complex issues. As part of its work, Texas Appleseed also conducts data-driven research to better understand inequities and identify solutions for concrete, lasting change. Texas Appleseed is part of a non-profit network of 17 justice centers in the United States and Mexico. Through its Fair Financial Services Project, Texas Appleseed is a state leader in advocating for fair market practices across many financial services areas, including fair auto insurance pricing, payday and auto title lending, protections for victims of financial abuse, and in support of fair debt collection practices. We appreciate the issuance of this RFI. It comes at an important time in market transitions, with a changing market due to the pandemic as well as expanded use of big data and telematics in insurance pricing. One of the major barriers faced by public interest organizations in analyzing fair and equitable pricing in the auto insurance market is access to data. Much data is either deemed proprietary or accessible only at great cost. This dynamic elevates the importance of the Federal Insurance Office, as a source of data and analysis focused on building a market that benefits all customers.
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