Center for Economic Justice, Consumers Union, and Consumer Federation of America write to express our dismay concerning the action of the Auto Insurance (C/D) Working Group (“Auto WG”) at the Summer National Meeting in Philadelphia and to ask that the decision and action be revisited with appropriate time for comment and deliberation.

The Auto WG adopted a data collection/affordability analysis proposal from industry that was radically different from a regulator-developed proposal that had been exposed for several months. The industry proposal was first posted on August 2, 2017, just four days before the Auto WG adopted it – after giving non-industry stakeholders four minutes to comment. The flawed process resulted in a flawed outcome and raises troubling questions about the role and authority of statistical agents.

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