When Congress created the Federal Insurance Office in 2010 as part of the Dodd-Frank financial regulation reform legislation, it directed the new agency to monitor the extent to which “traditionally underserved communities and consumers, minorities, and low- and moderate-income persons have access to affordable insurance products regarding all lines of insurance, except health insurance.”

FIO published a notice in April inviting public comments on this matter, with specific reference to automobile insurance. To its credit, FIO acknowledged that “the definition of the affordability of personal auto insurance remains unclear,” noting that when it asked its advisory council to define “affordability” in the context of insurance, the best it could do was to suggest that “affordability means that the cost of [personal auto insurance] is a reasonable percentage of a consumer's income”—which begs the question of what constitutes a “reasonable” percentage of income.

So FIO asked commenters to provide their own definitions of “affordable,” and to suggest “the metrics and data FIO should use to monitor the extent to which traditionally underserved communities, minorities, and low- and moderate-income persons have access to affordable automobile insurance.”

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