The Consumer Federation of America (CFA) and Center for Insurance Research (CIR) submitted comments to the Casualty Actuarial and Statistical Task Force (CASTF) at the National Association of Insurance Commissioners urging greater consumer rights and transparency on unknown and undisclosed risk characteristics in property and casualty insurance.

The Task Force should issue recommendations on appropriate disclosures and processes to remedy this rapidly developing crisis. Such recommendations are a critical first step in addressing the problems that occur when consumers are scored without any ability to understand the insurance risk scores, address any problems with them, or correct errors that have affected these scores. The use of unknown and undisclosed risk characteristics further undermines a critical component of the insurance system – voluntary risk mitigation.