Overview
Title
Agency Information Collection Activities; Submission for OMB Review; Comment Request; Collection of Data From Property and Casualty Insurers for Reports Concerning the Terrorism Risk Insurance Program
Agencies
ELI5 AI
The Department of the Treasury wants to know what people think about their plan to ask insurance companies questions about how they cover bad events like terrorism. They need this information to make sure everyone can still get and afford this kind of insurance.
Summary AI
The Department of the Treasury is requesting comments on its plan to collect data from property and casualty insurers as part of the Terrorism Risk Insurance Program. This data collection aims to support analyses required by the Terrorism Risk Insurance Act of 2002, which ensures the availability and affordability of terrorism risk insurance. The public can submit comments by April 4, 2025, and more information can be accessed through specific contacts and links provided in the notice. The collection involves various forms for different types of insurers and has an estimated annual burden of 51,070 hours across 1,015 respondents.
Abstract
The Department of the Treasury will submit the following information collection request to the Office of Management and Budget (OMB) for review and clearance in accordance with the Paperwork Reduction Act of 1995, on or after the date of publication of this notice. The public is invited to submit comments on this request.
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Sources
AnalysisAI
The Department of the Treasury has issued a notice inviting public comments on its intention to collect data from property and casualty insurers. This data collection is part of the Terrorism Risk Insurance Program (TRIP), which was established under the Terrorism Risk Insurance Act of 2002. The aim of TRIP is to support the availability and affordability of insurance for acts of terrorism, helping private markets stabilize and ensure adequate coverage capacity for such risks. The notice specifies that comments should be submitted by April 4, 2025, to ensure consideration.
Summary of the Document
The document announces an information collection request which the Treasury Department plans to submit to the Office of Management and Budget (OMB) as required by the Paperwork Reduction Act of 1995. The request seeks to gather specific data from insurers, which is crucial for compiling reports concerning the Terrorism Risk Insurance Program. This effort is an ongoing part of assessing and improving the Program's efficacy and relies on the participation of insurance companies to provide an accurate picture of the current market dynamics for terrorism risk insurance.
Significant Issues and Concerns
One notable issue is the lack of clarity about the revision of the currently approved collection. The document states that changes will be made but does not provide information on what these alterations entail. Understanding specific revisions is crucial for stakeholders to assess the potential implications of the data collection process.
The estimated burden on insurers also raises concerns. The time required varies significantly based on the size/type of insurer: from 32 hours for small insurers to 88 hours for larger ones. Such a disparity could pose operational challenges for larger insurance companies, potentially requiring them to allocate more resources to complete the collection requirements.
Moreover, the document mentions periodic analyses conducted by the Secretary of the Treasury but fails to detail the objectives or outcomes expected from these analyses. A clearer understanding of these goals would contribute to greater transparency and trust in the Program's data collection and analytical processes.
Potential Public Impact
The broad impact on the public is related to the continued provision of effective terrorism risk insurance. The data collected will help inform policy decisions to ensure that coverage remains available and affordable. Indirectly, this benefits businesses and individuals who rely on insurance protection against terrorism-related risks, contributing to economic stability.
Impact on Specific Stakeholders
For insurance companies, particularly large ones, the data collection imposes a substantial annual time burden. The differences in response time between small and large insurers could be significant, affecting their operational capacities.
On the other hand, the data collected aims to refine and enhance the TRIP, which serves the insurance industry by stabilizing risk pools and facilitating an environment where affordable coverage is sustainable. By participating in this data collection, insurers help shape a program that ultimately supports their ability to provide necessary coverage and manage their risks effectively.
In conclusion, while the notice serves a critical function in maintaining and improving the Terrorism Risk Insurance Program, potential uncertainties in its revisions and the significant variance in response times are key concerns for insurers that could influence their feedback during the comment period.
Issues
• The document mentions a 'revision of a currently approved collection,' but does not specify what changes or revisions are being proposed. Clearer information on what is being revised would be helpful.
• The estimated time per response varies greatly between small insurers (32 hours) and large insurers (88 hours). This significant difference might impose a heavier burden on large insurers, potentially affecting their operations. It would be useful to have justification or explanation for these differing time requirements.
• The description of the data collection includes mention of aiding the Secretary of the Treasury with periodic analyses but does not specify what these analyses aim to address or accomplish, which could be seen as lacking transparency.
• The section explaining the 'Frequency of Response’ lists 'Annually’ but does not explain if there are any potential penalties or consequences for insurers who fail to submit their responses on time.
• The document provides basic contact information for obtaining copies of submissions, but does not include specifics on how the collected data will be used or what protections exist for sensitive data submitted by insurers.
• The description section refers to reauthorization efforts but does not explicitly mention how these efforts have changed or impacted the scope of the data collection.