Category Archives: Risk-Based Pricing

NFIP Proposals Highlight Urgency of Collective Action on Resilience

By Lewis Nibbelin, Research Writer, Triple-I

Proposed reforms to FEMA’s National Flood Insurance Program (NFIP) would expand the role of private insurers in the flood market as part of a broader push for state and private sector participation in long-term disaster management and resilience.

Congress established NFIP in 1968, at a time when few private insurers were willing to write flood coverage. While private participation in the flood market has grown in recent years, NFIP has continued to cover more than half of all U.S. homeowners with flood insurance.

In their report released May 7, the FEMA Review Council described NFIP as “unsustainable” and “burdened by over $20 billion in debt” due to its “one-size-fits-all” approach to flood mapping, which “does not fully capture current or emerging flood hazards” on national and local scales. These shortcomings have contributed to inadequate insurance pricing and flood risk misconceptions among homeowners, exacerbating low flood insurance take-up rates in at-risk communities, the report said.

To ensure the availability of comprehensive flood protection, the report recommended establishing a depopulation program or a centralized flood insurance marketplace to shift more policies into the private market. Risk-based pricing for NFIP policyholders can also incentivize private involvement, the report said, as premiums adjust to reflect actual risk.

This transition builds upon NFIP’s Risk Rating 2.0 reforms, which aimed to make premium rates more actuarially sound and equitable by better aligning them with individual, property-level risk. As NFIP rates became further aligned with principles of risk-based pricing, some policyholders’ prices fell as many others rose, which boosted private market opportunities. Updates to the reforms based on new data could attract even greater private participation, the report said.

Private coverage gaps

Though flood was once considered an “untouchable” risk for the private market, advanced analytics capabilities and data sources have helped give them the comfort and flexibility they need to write the coverage. Federal regulations introduced in 2019 also allowed mortgage lenders to accept private flood insurance if the policies abided by regulatory definitions, propelling double-digit growth in private appetite.

Despite growth, private companies currently write only 27 percent of the flood market. Roughly 4.7 million homeowners have flood coverage through NFIP nationwide.

Mark Friedlander, Triple-I’s senior director of media relations, told USA Today Florida Network that private insurers are unprepared to take on all the risk NFIP covers, especially as flood risk severity rises.

“While private flood insurance is growing, NFIP remains vital for providing widespread, actuarially sound coverage against damages excluded from standard homeowners policies,” Friedlander said.

Ahead of a temporary NFIP lapse in 2025, a letter penned by organizations across the risk and insurance industry suggested the program’s absence “could further impact affordable housing, create additional challenges for small businesses, unnecessarily further increase the cost of homeownership, and must be avoided.”

Resilience key to insurance availability

For communities that invest in floodplain management, disbanding NFIP could disqualify homeowners from flood insurance premium discounts. FEMA currently incentivizes such practices through its voluntary Community Rating System, which rewards NFIP policyholders with corresponding discounts as high as 45 percent.

At a meeting with the FEMA Review Council before the 2025 lapse, NAIC members expressed support for these mitigation initiatives, with North Dakota Insurance Commissioner and NAIC Past President Jon Godfread adding “state insurance regulators are committed to expanding access to flood insurance through both the NFIP and private coverage.”

The recent restoration of FEMA’s Building Resilient Infrastructure and Communities (BRIC) program underscores the benefits of such multi-sector collaboration. Before its cancellation last year, the program had allocated more than $5 billion for investment in mitigation projects to alleviate human suffering and avoid economic losses from floods, wildfires, and other disasters.

Reinstated with several new rules to improve its impact, BRIC also “isn’t a perfect program, but it’s a necessary one,” said Daniel Kaniewski, CEO of Northstar Risk & Resilience, a former FEMA deputy administrator, and a Triple-I non-resident scholar. Though changes to the program may drive smarter resilience investment, he cautioned that “BRIC alone – or any federal program on its own – isn’t going to close the nation’s disaster resilience gap.”

“It’s going to take community leaders, emergency managers, businesses, nonprofits – and, of course, the insurance industry – pulling in the same direction,” Kaniewski said. “The burden can’t exclusively fall on property owners and federal taxpayers.”

Insurers have worked hard to develop partnerships that address these challenges. Strengthen Alabama Homes, for instance – financed by the insurance industry with more than $86 million in grants since 2016 – offers homeowners’ insurance discounts for those who build or retrofit their homes to voluntary IBHS construction standards for wind and hail resilience, prompting numerous states to implement their own programs.

Incentives and public-private collaboration will be critical to keeping insurance affordable and available amid the mounting toll of extreme weather. Swiss Re data indicates flooding, wildfires, and severe convective storms drove a record 92 percent of total global natural catastrophe insured losses in 2025, fueling a “decades-long trend of rising baseline risk.”

Learn More:

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N.Y. Natural Catastrophe Exposure Highlights
Risk-Based Pricing Benefit

By Lewis Nibbelin, Research Writer, Triple-I

New York may be less exposed to frequent natural catastrophes than states like Florida or California, but it is far from immune to massive catastrophe losses.

A recent white paper by risk modeler Karen Clark & Co (KCC) cautions against underestimating the Empire State’s vulnerability – or that of other states not typically identified with large-scale natural disasters. A future 1-in-100-year hurricane event in New York could cost insurers more than $100 billion, KCC reported, with a 1-in-250-year event potentially costing twice as much.

“Beyond hurricanes, New York also experiences substantial impacts from both severe convective storms and winter storms, which together generate almost $1 billion in average annual property losses in the state,” KCC notes.

As state lawmakers consider strengthening requirements for prior approval of premium rate increases to rein in rising costs, KCC suggests that cost reduction strategies that account for these potential impacts would help ensure “property insurance remains both available and affordable.”

Underlying cost drivers

New York is exposed to nearly $9 trillion in potential insured losses, $6 trillion of which is concentrated along the coast. Contributing factors include property location and associated rebuilding costs, demonstrating, in part, demographic shifts placing more people in harm’s way, KCC said.

“Even if rates remain constant, premiums will rise over time to reflect the increasing cost of construction,” the report said. It added that such costs for an average single-family home have doubled over the past decade.

With trillions in loss exposure, the state faces outsized impacts, even from less intense storms. For instance, Hurricane Sandy in 2012 – despite making landfall in New Jersey as a Category 1 storm – generated almost $10 billion in insured losses in New York. Based on current exposure, insured losses in New York would exceed $13 billion, with total losses climbing to $31 billion.

A Category 3 hurricane that made landfall in the state in 1938 would produce more than $20 billion in insured losses today, KCC said. The state’s “worst-case scenario,” however, is if a similar storm hit close to Rockaway Beach in New York City, as losses in the hundreds of billions would ripple through “the most populated areas of the state.”

Sustaining market health

In testimony to the New York State Senate in November 2025, the American Property Casualty Insurance Association (APCIA) estimated that such an event “would wipe out 69 years of homeowners’ insurance return on net worth. ” APCIA noted that New York State is second only to Miami in vulnerability to a hurricane exceeding $100 billion in losses.

At the same state senate hearing, Triple-I Chief Insurance Officer Patrick Schmid testified on market adjustments insurers made in the wake of Hurricane Sandy, such as updating rates and establishing reserves for Sandy-related claims that extended beyond the year of impact.

These changes have allowed state homeowners’ insurance premiums to remain “relatively average and reasonable as a percentage of household income,” contradicting “the narrative of an affordability crisis in New York’s homeowners’ insurance market,” Schmid explained.

“In other words, the ‘profitable decade’ reflects a market that learned from a major catastrophic event and adjusted accordingly,” Schmid said. “This is how insurance markets should function.”

Importance of risk-based pricing

Insurance pricing must reflect increased risks to maintain policyholder surplus, or the funds regulators require insurers to keep on hand to pay claims. Regulatory constraints on risk-based pricing in some states have forced insurers to write fewer policies or withdraw from state markets entirely, leading to less affordable and available coverage.

Unlike its homeowners’ market, New York’s auto expenditures rank among the highest in the country, driven by repair costs as well as accident frequency and fraud, according to a Triple-I Outlook. Proposals to give New York regulators the authority to block auto premium rate changes could erode surplus and further push insurers to rethink their risk appetite in the state, which already imposes a restrictive “excess profit” law.

The role of profit in insurance pricing is not merely to reward insurers for the risks they assume. As KCC puts it, profit is “the mechanism through which insurers compensate capital providers for risk.” Rather than intervene in insurance markets, policymakers should aim to provide “a regulatory environment that allows insurers flexibility to set adequate rates.”

Learn More:

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Illinois Lawmakers
Reject Risk-Based
Pricing Challenge

By Lewis Nibbelin, Research Writer, Triple-I 

Illinois insurers narrowly avoided increased government involvement in insurance pricing as state legislators rejected “an extreme prior-approval system found nowhere else in the country,” according to a joint statement from the American Property Casualty Insurance Association, the National Association of Mutual Insurance Companies, and the Illinois Insurance Association.

If approved, the bill would have given regulators the authority to block rate change and order refunds from insurers for premiums deemed excessive, effectively generating “fewer choices and greater instability,” the statement continued.

While calls for the bill began in July, following homeowners’ insurance rate hikes, Illinois has a history of legislative challenges to actuarially sound pricing. Similar legislation in Louisiana passed that same month, amid record rate filing rejections in Pennsylvania and two California lawsuits accusing insurers of deliberately underinsuring policyholders to maximize profits.

Such trends underscore pervasive misunderstandings surrounding risk-based pricing, the practice under which insurers offer different prices for the same coverage based on risk factors specific to the insured. Without it, insurers could not adequately cover mounting natural catastrophe losses, inflationary pressures, and other rising costs, leading to an insufficient policyholder surplus to pay claims. When surplus falls below a certain threshold, insurers must raise premium rates, adjust their coverage availability, or, in extreme cases, become insolvent.

Under this pricing methodology, Illinois benefits from better coverage affordability compared to the national average and a competitive insurance market of more than 200 operating insurers.

“Illinois has a very stable insurance marketplace,” said Triple-I CEO Sean Kevelighan. “Restrictive legislation could lead to a California-like regulatory environment that would impact insurance affordability and availability in the state, rather than help consumers as intended.”

Rather than involve themselves in the complexity of insurance pricing, policymakers in Illinois and elsewhere would do a greater service to their constituents by exploring and investing in risk reduction through cost-saving mitigation and resilience investments. The property/casualty insurance industry can be a valuable partner in such beneficial approaches.

Learn More: 

New Illinois Bills Would Harm — Not Help — Auto Policyholders

Resilience Investment Payoffs Outpace Future Costs More Than 30 Times

L.A. Homeowners’ Suits Misread California’s Insurance Troubles

California Insurance Market at a Critical Juncture

Triple-I Brief Explains Benefits of Risk-Based Pricing of Insurance

By Jeff Dunsavage, Senior Research Analyst, Triple-I

“Risk-based pricing” is a basic insurance concept that might seem intuitively obvious when described – yet misunderstandings about it regularly sow confusion and spark calls for government intervention that would likely do consumers more harm than good.

Simply put, it means offering different prices for the same level of coverage, based on risk factors specific to the insured person or property. If policies were not priced this way, lower-risk drivers would necessarily subsidize riskier ones.

Confusion ensues when actuarially sound rating factors intersect with other attributes in ways that can be perceived as unfairly discriminatory. A new Triple-I Issues Brief sorts out the reasons for such confusion and explains why legislative involvement in insurance pricing is not the answer to rising premiums. In fact, the report says, such involvement would tend to drive premiums up, not down.

Worries about equity

Concerns have been raised about the use of credit-based insurance scores, geography, home ownership, and motor vehicle records in setting home and car insurance premium rates. This confusion is understandable, given the complex models used to assess and price risk. To navigate this complexity, insurers hire teams of actuaries and data scientists to quantify and differentiate among a range of risk variables while avoiding unfair discrimination.

Triple-I’s brief shows how one frequently criticized rating factor for auto insurance – insurance-based credit scores – effectively tracks collision claim frequency.  Drivers with the worst 10 percent of scores have twice as many collision claims as the best 10 percent. The sophisticated tools actuaries and underwriters use ensure fair, accurate pricing, and insurers do everything they can to see that all valid claims are paid on time and in full.

Climate and inflation

Areas that were once less vulnerable to certain natural perils – such as wildfire and hurricane-related flooding – increasingly are being affected by these costly events. Furthermore, more people have been moving into at-risk areas on the coasts and in the wildland-urban interface (WUI), putting more property into harm’s way.

Insurance pricing must reflect these increased risks to maintain policyholder surplus – the funds regulators require insurers to keep on hand to pay claims. In some states, this increased risk – combined with regulatory decisions that make it hard to raise premium rates to the levels needed to adequately meet it – has forced some insurers to reduce their exposure and not write as many policies and even withdrawing from states completely. In these states, not only has homeowners’ coverage become less affordable – in some cases, it has also become less available.

Another factor driving up premiums is inflation. As material and labor costs rise, the cost to repair and replace damaged homes and vehicles increases. If premium rates don’t reflect these increased costs, insurers would quickly exhaust their policyholder surplus. If their losses and expenses exceed their revenues by too much for too long, they risk insolvency.

A role for governments

Policymakers naturally want to address the impact of rising costs – including insurance premiums – on their constituents. A good start would be to help reduce risk by modernizing building codes and incorporating resilience into their infrastructure investments. Reduced risk and less costly damages would, over time, translate into lower premium rates.

Governments also can work with insurers and other stakeholders to incentivize homeowners to invest in mitigation and resilience. The Strengthen Alabama Homes program is a great example of one such collaboration between state government and the insurance industry that has measurably improved results and is beginning to be imitated by other states.

Learn More:

Calls for Insurance-Price Legislation Would Hurt Policyholders, Not Help

Easing Home Upkeep to Control Insurance Costs

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Outdated Building Codes Exacerbate Climate Risk

L.A. Homeowners’ Suits Misread California’s Insurance Troubles

Data Granularity Key to Finding Less Risky Parcels in Wildfire Areas

Calif. Risk/Regulatory Environment Highlights Role of Risk-Based Pricing

Actuarial Studies Advance Discussion on Bias, Modeling, and A.I.

Accurately Writing Flood Coverage Hinges on Diverse Data Sources