6 CONSUMER FEDERATION OF AMERICA 2018 ANNUAL REPORT proposed rulemakings on the Banks’ affordable housing programs; drafted substantial comments on an FHFA proposed rule on the GSE’s use of credit scoring, which was signed onto by National Fair Housing Alliance, Leadership Conference on Civil and Human Rights, and Woodstock Institute. CFA continued to play a leadership role in bringing together various stakeholders on housing- related issues, through its continued sponsorship of both the Consumer Lender Roundtable and the annual Housing Renaissance meeting. Insurance: CFA continued leading a campaign to ensure that auto insurance – required in all states but New Hampshire – is fair, transparent, and affordable. Focusing particular attention on lower-income drivers, we advocated for auto insurance rates that are based on driving-related factors, not the socio-economic and personal characteristics of customers. To that end, we researched auto insurers’ problematic and unfair pricing practices and published reports documenting discriminatory practices. All of our research on this issue was sent to state insurance commissioners and widely reported by the news media. Our insurance experts also delivered to commissioners a detailed analysis of the consumer savings that have resulted from California’s Proposition 103, offering it as a model of how strong regulation and steps to improve the market competition can benefit consumers. We also supported the work of advocacy groups and assisted regulators and lawmakers in California, Delaware, Florida, Maryland, Minnesota, Montana, New York, Ohio, and Texas on state-level initiatives. On other insurance issues, CFA continued to provide detailed comments to policymakers on efforts to reform the National Flood Insurance Program. Through media outreach, we communicated important consumer protection steps for homeowners and regulators to take in the wake of the catastrophic hurricanes and fires of 2018. Our detailed opposition (before states and the FTC) to the anti-competitive title insurance merger of Fidelity and Stewart appears to have slowed down the merger and may have stopped it. Testimony we provided in New York led to a reduction in title insurance rates. We also called on states to lower insurance rates to reflect the windfall profits insurers were enjoying from the 2018 reduction in the federal corporate income tax rate.