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When Congress created the Federal Insurance Office in 2010 as part of the Dodd-Frank financial reform legislation, it asked the new agency to monitor whether traditionally underserved consumers, communities, minorities, andlow- and moderate-income persons have access to affordable insurance products in all lines except health insurance.

FIO published a notice last April inviting public comments on the matter, with specific reference to Auto insurance. FIO noted that when it asked its advisory council to define insurance affordability, it could only suggest that “affordability means that the cost is a reasonable percentage of a consumer’s income.” This begs the question of what constitutes a “reasonable” percentage.

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