Tell HUD to exclude homeowners' insurance from the Disparate Impact Rule

Thank you for the opportunity to respond to the request for public comments set forth in the Notice of Proposed Rulemaking issued by the U.S. Department of Housing and Urban Development (HUD) and titled Reinstatement of HUD's Discriminatory Effects Standard.

I understand that HUD proposes reinstating the 2013 version of its Disparate Impact Rule that would revert to the Obama Administration's 2013 version of the rule that had previously been superseded by the Trump administration's 2020 version. As you know, that 2020 version was issued, after intensive public comment review, to better align the Disparate Impact Rule with the 2015 US Supreme Court decision in Inclusive Communities which recognized important limitations on the application of disparate impact liability under the Fair Housing Act. I have grave concerns about the proposal to revert back to the older version which does not align with the Supreme Court's guidance. 

I have been listening to the important conversations taking place across the country about equity and social justice, and I believe all Americans should be treated fairly when it comes to home, auto, and business insurance. However, I am concerned that moving backwards to the 2013 Rule would make matters worse instead of better and ignore the Supreme Court's caution against "inject[ing] racial considerations into every housing decision" and "perpetuat[ing] race-based considerations rather than mov[ing] beyond them," thereby unfairly penalizing many Americans like myself, possibly resulting in higher costs for all. 

For these reasons, I believe that HUD should exempt actuarial risk-based pricing and underwriting of homeowners' insurance from the Disparate Impact Rule.