Risk & Regulatory Consulting, LLC (“RRC” or “we”) supports the efforts of the Big Data (EX) Working Group (“Working Group”) to outline a process for determining whether changes to the current regulatory framework are needed to address the use of consumer and non-insurance data, and if so what form these changes should take. We have reviewed the discussion document and offer the following comments for your consideration. We would be glad to answer any questions, and we appreciate the opportunity to offer our comments.

We appreciate the efforts of the Working Group to thoughtfully consider the far reaching implications of new data sources that are available for policy rating. The data that is now available is far beyond that envisioned when current rating laws were drafted, and as time progresses there will be other available data that has not been considered to date. As such, innovative regulatory approaches are needed to address the impact of new sources of rating data on consumer insurance pricing. The work of this group will impact insurers, regulators and, most importantly, consumers, for decades to come.