Washington, D.C.— Eighteen consumer, civil rights, and community organizations jointly submitted comments Tuesday to the National Association of Insurance Commissioners (NAIC) Special Committee on Race and Insurance urging them to focus its efforts on creating tools to help states and insurers identify and combat systemic racism in insurance.

The letter calls for the Special Committee to “avoid meetings with debates about the existence of systemic racism but instead move quickly to identify the places it appears and develop the strategies needed to address it...following the murder of George Floyd.” The organizations continued, “NAIC leadership offered strong words regarding regulators’ commitment to address systemic racism in insurance. Those words must be supported with a commitment of resources and time to this project.”

Specifically, the groups’ comments call for the following from the NAIC:

• Examination of the ways systemic biases impact underwriting decisions, premiums, claims handling, and fraud investigation;
• Detailed recommendations to states and insurers on how to test for disparate impacts and eliminate unfair discrimination and racism in the industry; and
• More robust data collection of insurance market outcomes and data transparency, so advocates, insurers, and regulators can more effectively stop discrimination.

The nation now realizes that systemic racism exists throughout society, and insurance is no exception. Studies over many years have shown elements of this in pricing, placement of agents, redlining and other aspects of insurance. But systemic racism is not found in just a few elements of insurance; it casts its shadow across all aspects of insurance and needs to be confronted in a systematic and holistic manner, according to Consumer Federation of America, which will provide testimony reflecting the groups’ comments to the NAIC at a Thursday meeting of the Special Committee.

The groups signing the letter are: