We appreciate the Department's investigation of unintentional bias in auto insurance and its identification of a racial premium gap, where Black and Latino consumers pay more substantially more for auto insurance than white consumers. However, the report does not examine a variety of socioeconomic rating factors and other factors that may contribute to the premium gap seen in this market.

The Consumer Federation of America urges DISB to follow up this research with an investigation of factors that drive the racial premium gap. This investigation and analysis should examine insurers’ use of socioeconomic rating factors, including: 1) consumer credit information, 2) education level, 3) job or occupation, 4) homeownership status, 5) prior carrier and coverage limits, and 6) lapses in insurance coverage. Additionally, while this initial report examined the role of gender and marital status, we believe it would be valuable to include those characteristics in future research.