The Consumer Federation of America strongly opposes the adoption of the Auto Study Group compendium of reports for several reasons. First, this document is not a compendium of reports by any means, but, instead, an assemblage of insurance industry and NAIC reports, including three that are more than fifteen years old. Further, the included documents and reports generally do not respond to the underlying purpose of the study group: “to review issues relating to low-income households and the auto insurance marketplace and to make recommendations as appropriate.” Nor does the compendium meet its own stated purpose of providing “a resource for state insurance regulators seeking to know more about issues concerning the availability and affordability of automobile insurance.”

