William Jaskar Agency Comments on HUD’s Implementation of the Fair Housing Act’s Disparate Impact Standard
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I only collect the information which is required by the application for insurance. If I can process an application without obtaining the social security number--I'll leave that section blank. I do advise clients that inputting a social security number may help them achieve better rates, but the request is completely voluntary on the part of the insured (providing it's not required on the application). To further highlight my protection efforts of sensitive information, my agency has a strict burn policy that I have carried over from my days in and working for the military. If I obtain sensitive information such as credit card data from a client, it is written on a specifically colored notepad. At the closing of each night the information is shredded so that the information is destroyed. I treat their information with the same level of security with which I treat my own. My clients deserve to know that I care about their privacy.
If I was required to ask clients about their ethnicity or other categorically identifying information which should have no baring whatsoever in the application process--would not be well received. Collecting this information would lead to a higher probability that the information could be inaccurate. Ultimately, I believe the collection of this impertinent information would unnecessarily impact the quoted premium and lead to more complications. Additionally, storing such personal information would likely lead to unforeseen abuses. I cannot be convinced that requesting personal identifying information such as: race, color, religion, creed, national origin, sex, sexual orientation, gender identity, gender expression, marital status or partnering type, should be worthy of any weight in determining premium for an insurance policy.
At the agency level, we should be focused on protecting our clients. Not exploiting the client for personal information which as zero impact on the reconstruction cost of a home, the ability to drive a car, how an umbrella policy would extend their liability exposure, or their desire to properly insure a travel trailer. Applying the disparate impact standard to personal lines insurance policies is the opposite of what we need to do. We need to streamline the insurance process so that we can protect more clients. You must reject applying the disparate impact standard to homeowner's insurance.
I will add that I'm open to an education. Please feel free to provide me statistical information that supports collecting this type of information--perhaps I'll reconsider.
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The proposed rule can be viewed at: https://www.regulations.gov/document?D=HUD-2019-0067-0001
TARGETED NEWS SERVICE,


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