Moreover, it is simply inaccurate and misleading to suggest data reporting to ISO has suddenly become more complex because data is now reported electronically. Data is reported electronically because companies want it that way.

We eliminated paper reporting more than five years ago for greater efficiency, not because a more complex stat plan could not be completed on a paper form.

To be fair to our participating insurers, we accommodated paper reports for two years after the switch to electronic delivery for those companies needing more time to convert. What's more, we have stressed making our system user friendly to all sizes of companies and a broad range of electronic capabilities.

In fact, insurers have recently requested the ability to report statistics directly from their PCs and in AS 400 format, and we have accommodated that.

Mr. Gilbert erroneously states that the ISO statistical plan for other-than-auto and auto mandates the completion of a 300-character record in ISO codes, with each code representing a field. In fact, the OTA plan record contains 150 positions, only half of which are used for ISO data. In the auto stat plan, less than half of those positions are required data fields. The rest are for company use or blanks.

Another serious misconception created by Mr. Gilbert's article is that the universe of insurers are burdened by having to report under the new stat plans. In fact, less than 40 companies are affected by the new personal auto requirements and less than 50 are affected by the OTA plan. And since some companies report in both categories, the total is much less than 90.

Certain of Mr. Gilbert's assertions hardly deserve serious response. Any insurance professional knows that gender, marital status and age are essential rating variables, so, of course, regulation, and hence the stat plans of all stat agents, require these items to be reported.

In 32 years of data collecting and reporting as statistical agent to all 50 state insurance commissioners, ISO has established an exemplary record of data compliance at reasonable and competitive costs, precisely because of our frequent and proactive outreach to all insurers to help them in the data reporting process.

By grossly overstating the complexity of the ISO data reporting process, Mr. Gilbert may hope to find customers for his consulting business based on the belief that data reporting is more costly and time consuming than it actually is.

To Mr. Gilbert's three options for help in data reporting, we suggest a fourth: Before you incur costly counsel needlessly, call ISO. We have the expertise and resources to train, assist and provide consulting to any company of any size requiring data reporting. You'll get straight answers, clear guidance and no tricks.

Carole J. Banfield

Executive Vice President

Government Relations

and Data Management

Insurance Services Office, Inc.

Jersey City, N.J.

Reproduced from National Underwriter Property & Casualty/Risk & Benefits Management Edition, October 22, 2001. Copyright 2001 by The National Underwriter Company in the serial publication. All rights reserved.Copyright in this article as an independent work may be held by the author.

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