From tracking NAIC data calls since the 2020 wildfire season, this one is different. On March 25, 2026, the NAIC sent letters to every homeowners carrier in the country notifying them of the Homeowners Market Data Call (HMDC), the first time regulators have demanded peril-level granularity across all participating states on a single standardized template with a no-extensions deadline. The Homeowners Market Data Call (C) Task Force finalized submission requirements at its March 24, 2026 Spring National Meeting session, and the clock started immediately: carriers writing at least $50,000 in direct written homeowners premium in any participating jurisdiction have until June 15, 2026 to submit eight years of data through the NAIC's Regulatory Data Collection portal (NAIC).
This is not a survey. It is a mandatory data call backed by each participating jurisdiction's statutory examination authority. The 50 participating jurisdictions include 48 states, the District of Columbia, and Puerto Rico, covering effectively the entire U.S. homeowners market. Alabama and Tennessee are the notable absences. Every other state is in, from California and Florida to Wyoming and North Dakota (NAIC State Statutes Documentation).
The significance is structural: for the first time, regulators will have a standardized dataset that allows cross-state comparison of peril-level loss trends, non-renewal patterns, coverage erosion, deductible shifting, and mitigation discount penetration. Every previous NAIC homeowners data effort relied on Annual Statement aggregates or targeted surveys limited to specific states. This call changes the baseline.
What the Data Call Requires: 113 Fields Across Four Parts
The HMDC submission template contains 113 data fields organized into four substantive parts, plus a respondent information section. The NAIC published the full field definitions, formatting requirements, and validation rules alongside the call, and held a submission webinar on April 9, 2026 to walk carriers through the template (NAIC Data Call Portal).
The data is reported at the zip-code level, by policy form (DP-1 through DP-3 and HO-1 through HO-8), by year (2018 through 2025), and separately for new versus renewed business. This granularity means that a single carrier writing homeowners in all 50 jurisdictions across eight years, multiple policy forms, and thousands of zip codes will generate an exceptionally large submission. Each response must be filed on an individual company basis, not at the insurance group level.
| Section | Fields | Key Data Elements |
|---|---|---|
| Part I: Premium, Coverage, Deductibles | 12-70 | Written premium in-force, policies in force, Coverage A/B/C/D limits, wind/wildfire/earthquake exclusion counts, RC vs. ACV breakdowns, deductible distributions by peril |
| Part II: Claims and Losses | 71-82 | Paid claims and losses by peril: fire (excluding wildfire), wind/hail, water damage/freezing, wildfire, all other |
| Part III: Cancellations and Non-Renewals | 83-90 | Non-payment cancellations, company-initiated cancellations by timing window, non-renewal counts, premium for cancelled policies |
| Part IV: Mitigation Discounts | 91-112 | State-required and voluntary discounts for fortified standards, wind, wildfire, impact/hail, and water mitigation |
The $50,000 threshold is deliberately low. It captures nearly every active homeowners writer in each participating state, including smaller domestic carriers and surplus lines writers that would typically fall outside targeted data requests. A company triggers the filing obligation if it wrote at least $50,000 in direct written premium on homeowners line 4 of the Annual Statement during any year from 2018 through 2025, or if it wrote at least $50,000 in premium on dwelling or homeowners policies (DP-1 through DP-3, HO-1 through HO-8) outside line 4 during the same period (NAIC Field Definitions).
The Eight-Year Lookback: 2018 Through 2025
The eight-year reporting window is the feature that transforms this from a market snapshot into a trend analysis tool. By requiring data from 2018 through 2025, the NAIC captures four distinct market phases:
Pre-pandemic baseline (2018-2019). These years provide the last "normal" baseline before supply chain disruption, remote work migration, and pandemic-era claims anomalies altered homeowners loss patterns.
Pandemic period (2020-2021). Work-from-home increased occupancy and altered loss frequency patterns. Water damage claims rose as more plumbing ran during business hours. Fire losses from cooking and electrical sources shifted. Non-renewal moratoriums in several states temporarily suppressed carrier exit activity.
Post-pandemic inflation (2022-2023). Construction material costs surged, with lumber prices tripling from pre-pandemic levels before partially retreating. Labor shortages in roofing and general contracting pushed claim severity higher. Carriers accelerated rate filings, and several states saw their first meaningful waves of company-initiated non-renewals since the early 2000s.
Climate-driven acceleration (2024-2025). Severe convective storm losses exceeded $50 billion for the third consecutive year in 2025 (Triple-I). The January 2025 Los Angeles wildfires generated approximately $40 billion in insured losses (Swiss Re). FAIR plan enrollment reached 2.68 million policies nationally, up 51% from 2015, with total premiums of $7.65 billion (Insurance Information Institute). California, Florida, and Louisiana together accounted for more than $6.5 billion in FAIR plan premiums.
Patterns we have seen in recent quarterly carrier earnings suggest that the 2024-2025 data will show the sharpest divergence between peril categories. Wind and hail accounted for 42.5% of national homeowners losses in 2023, water damage and freezing for 22.6%, and fire and lightning for 21.6%, but fire and lightning carried an average claim severity of $88,170 compared to just $14,747 for wind and hail (III). The eight-year window will reveal how those proportions have shifted as wildfire and severe convective storm frequency increased.
Peril-Level Claims Data: What the Five Categories Will Reveal
The claims and losses section (Part II) requires carriers to break down paid claims counts and losses paid into five peril categories. This is the core innovation of the data call. Previous NAIC data collections reported aggregate homeowners claims without peril attribution. The HMDC forces decomposition into fire (excluding wildfire), wind and hail, water damage and freezing, wildfire, and all other perils. Peril-specific claim counts must sum exactly to total claims, and peril-specific losses must sum exactly to total losses (NAIC Validation Rules).
The separation of wildfire from fire is significant. On the Annual Statement, both categories collapse into a single fire loss figure. Regulators have never had a standardized way to isolate wildfire losses from kitchen fires, electrical fires, and other non-climate-related fire events across all jurisdictions simultaneously. For states like California, Colorado, Oregon, and New Mexico, this separation will produce the first clean wildfire-specific loss ratio data that regulators can use to evaluate rate filing adequacy.
The wind and hail category corresponds roughly to severe convective storm (SCS) exposure, though it also captures non-SCS wind events and hurricane-related wind damage. With SCS insured losses surpassing tropical cyclones cumulatively since 2000 and exceeding $50 billion in each of the last three years (Aon, Triple-I), the peril-level data will show regulators exactly which states bear disproportionate wind/hail loss concentration.
Claims are reported in the year they closed, not the year they opened. Losses are direct losses paid less salvage and subrogation, excluding case reserves, unpaid amounts, and loss adjustment expenses. This paid-basis reporting convention simplifies cross-carrier comparison but means that the 2024 and 2025 data for long-developing perils like wildfire may not fully reflect ultimate losses.
Non-Renewals and Market Withdrawal: The Availability Crisis Dataset
Part III captures the data elements that directly measure market availability. Regulators have been forced to track non-renewals through ad hoc surveys, press reports, and carrier-by-carrier rate filing disclosures. The HMDC creates the first systematic accounting of how carriers are managing their homeowners books across all 50 jurisdictions.
Company-initiated cancellations are broken into three timing windows: first 59 days, 60 to 90 days, and more than 90 days after the policy effective date. This granularity matters because early cancellations (within 59 days) typically reflect post-binding underwriting decisions, while late cancellations (after 90 days) may indicate mid-term risk reassessment driven by catastrophe model updates or inspection findings. Only cancellations resulting in an actual lapse of coverage are counted; cancel-rewrites are excluded.
Non-renewal counts, tracked separately from cancellations, will reveal the geography of carrier retreat. Florida's Citizens Property Insurance Corporation held 1.34 million policies with $4.6 billion in premiums by fiscal year 2024. California's FAIR Plan reached 431,300 policies with $1.42 billion in premiums. Louisiana's FAIR Plan held 161,647 policies with $518 million in premiums (III). When the HMDC data is available, regulators will be able to map non-renewal concentration at the zip-code level and identify whether private market exits cluster in specific peril zones or spread more broadly across entire states.
Coverage Erosion: Replacement Cost, ACV, and the Deductible Shift
Part I contains fields that many trade press accounts of the data call have overlooked but that actuaries will recognize as critical. Carriers must report the count of policies in force with replacement cost (RC) coverage on dwelling, separately from policies with actual cash value (ACV) coverage on dwelling. The same split applies to roof coverage and siding coverage.
This distinction tracks a trend that has accelerated since 2022: carriers downgrading from replacement cost to actual cash value, particularly on roofs. In states with high hail frequency, several carriers have moved to ACV roof endorsements that depreciate roof value based on age, effectively shifting the replacement cost gap to the policyholder. The HMDC data will quantify how widespread this shift has become. If 30% of policies in a given state now carry ACV roofs versus 10% five years ago, regulators have direct evidence of coverage erosion even if premium levels appear stable.
The deductible fields are equally granular. For each of three peril categories (all perils, hurricane/named storm, and wind/hail), carriers report the number of policies falling into six deductible buckets: $500 or lower, $500 to $2,000, $2,000 and above (fixed dollar), 2% or less, 2% to 5%, and 5% and above (percentage-based). Earthquake deductibles have their own seven-bucket distribution. This data will show regulators where percentage deductibles, which can translate to $10,000 or more on a $500,000 home, have proliferated as carriers managed their aggregate exposure.
The NAIC FAQ clarifies that percentage deductibles should be converted to dollar amounts for certain calculations, but the distribution buckets allow regulators to see the underlying structure. A state where 40% of policies carry hurricane deductibles above 5% of dwelling value presents a fundamentally different consumer protection profile than a state where most deductibles are $1,000 flat.
Mitigation Discounts: The First Standardized Penetration Baseline
Part IV collects both state-required and voluntary mitigation discount data across five categories: fortified standards, wind, fire/wildfire, impact/hail, and water. For each category, carriers report the count of policies receiving the discount and the average percentage discount.
This section directly connects to the NAIC's parallel work on the Strengthen Homes Act model law, which the Executive Committee approved for development at the Spring 2026 meeting. That model law would create standardized frameworks for state-run mitigation grant programs and require actuarially justified premium discounts for qualifying improvements. The HMDC mitigation data will provide the baseline that the Strengthen Homes Act framework needs to function: without knowing current mitigation discount penetration by state, regulators cannot assess whether grant programs are reaching policyholders or whether carriers are offering adequate premium relief for qualifying improvements.
The IBHS FORTIFIED Home program has generated the strongest evidence to date on mitigation effectiveness. An IBHS study of Hurricane Sally (2020) found that FORTIFIED-designated homes experienced 55% to 74% fewer claims and 51% to 72% lower loss ratios compared to non-FORTIFIED homes. Alabama's Strengthen Alabama Homes program has funded more than 5,000 roof upgrades. Oklahoma, Florida, and South Carolina operate similar programs. The HMDC data will show regulators, for the first time, how discount penetration varies across states with active programs versus states without them.
Compliance Challenges: What Carriers Face Before June 15
The 82-day window between the March 25 letter and the June 15 deadline, with no extensions permitted, creates significant operational pressure for carriers. Several compliance challenges are already surfacing in industry conversations.
Peril attribution in legacy systems. Many carriers do not tag claims by peril at the granularity the HMDC requires. Separating wildfire from general fire may require manual review of claims files in states where the distinction was not coded at first notice of loss. Wind/hail versus "all other" attribution for older accident years may similarly require reconstruction from adjuster notes rather than structured data fields.
Zip-code-level reporting. The NAIC requires data at the risk location zip code, not the mailing address. For carriers that historically indexed policies by mailing address or county, mapping eight years of historical data to risk-location zip codes may require geocoding exercises against property databases.
Individual company versus group reporting. The data call requires submission on an individual company basis. Groups that write homeowners through multiple legal entities must prepare separate submissions for each entity, even if they manage underwriting and claims on a consolidated basis.
RC/ACV and deductible field population. Many carriers' policy administration systems do not store historical RC versus ACV elections, extended replacement cost percentages, or deductible structures in readily queryable formats for policies from 2018 and 2019. Retrieving these fields across eight years of policy terms may require extraction from archived rating engines or endorsement-level transaction records.
The NAIC published an FAQ document (updated April 23, 2026), a field formatting and validations specification, a CSV upload template, and RDC user guide to assist carriers. Submissions go through the RDC portal at rdc.naic.org using the PAC data call group with option HMDC_2026. Automated validation checks return a "File Rejected System" status for submissions that fail formatting or consistency rules, such as peril-level claims not summing to total claims (NAIC FAQ).
What Eight Years of Standardized Data Will Reveal
The combination of peril-level losses, non-renewal tracking, coverage composition, and mitigation discount data across 50 jurisdictions and eight years creates analytical possibilities that have not previously existed in regulatory data.
Cross-state subsidy patterns. Zip-code-level premium and loss data will show where loss ratios diverge sharply from premium adequacy. States with suppressed rates relative to peril exposure will be quantifiably identifiable, not through carrier-specific rate filings, but through cross-state comparison of the same standardized fields.
Climate-peril attribution. Separating wildfire from fire and tracking wind/hail losses distinctly allows regulators to attribute loss trends to climate-sensitive perils versus attritional, non-climate-related perils. This distinction is essential for rate filing review in states that restrict or require forward-looking catastrophe models in pricing.
Availability crisis mapping. Non-renewal and company-initiated cancellation data at the zip-code level, combined with FAIR plan enrollment growth, will show regulators exactly where the private market is contracting. This data supports the NAIC's Natural Catastrophe Risk and Resilience Task Force's stated objective of developing "property market data intelligence so regulators can better understand how markets are performing in their states" (NAIC CIPR).
Deductible cost-shifting quantification. The detailed deductible distribution data will reveal how much catastrophe exposure has been transferred from carriers to policyholders through percentage deductibles. Regulators concerned about affordability and adequate coverage can now benchmark deductible structures across states rather than relying on anecdotal evidence from individual rate filings.
Mitigation return on investment. Comparing loss ratios in zip codes with high mitigation discount penetration against zip codes with low penetration, within the same peril zone, will produce the first large-scale empirical evidence of whether premium discounts correlate with actual loss reduction in a multi-state dataset.
Why This Matters for Actuarial Practice
The HMDC data call has direct implications for actuaries in several practice areas.
Rate filing support. Pricing actuaries at carriers subject to the data call should anticipate that regulators will use the HMDC data to benchmark rate filings. If a carrier's indicated wildfire loss ratio in California is 20 points below the HMDC statewide average, regulators will have a specific, standardized data point to question the assumption. Previously, rate filing review relied on the individual carrier's data and the regulator's judgment. The HMDC introduces a cross-carrier benchmark that did not exist before.
Reserve adequacy. The peril-level claims data, once published in aggregate by the NAIC, will allow reserving actuaries to benchmark their company's loss development patterns against industry peril-specific trends. This is particularly valuable for wildfire reserves, where individual carrier loss experience may lack the volume necessary for credible development factor selection.
Catastrophe model validation. The HMDC dataset, once available, will serve as a calibration check for catastrophe models. If vendor models estimate statewide wind/hail losses at one level but the HMDC data shows consistently higher actual losses across the eight-year window, actuaries have empirical grounds for model adjustment in rate filings.
Market conduct and availability monitoring. For actuaries working in regulatory roles, the non-renewal and cancellation data creates a surveillance tool. A carrier that doubles its non-renewal rate in wildfire-exposed zip codes while maintaining stable premiums in low-risk areas is engaging in risk selection that may warrant regulatory inquiry, and the HMDC data will make that pattern visible across all carriers simultaneously.
Compliance operations. For actuaries involved in regulatory compliance at carriers, the immediate priority is ensuring data quality in the June 15 submission. The 113-field template with automated validation checks means that incomplete or inconsistent submissions will be rejected. Carriers that have not begun their data extraction and mapping should treat this as an urgent operational priority.
The HMDC represents the NAIC's most ambitious property market data collection effort. Its success depends on carrier compliance quality and the NAIC's ability to aggregate and share the data effectively across participating jurisdictions. If it works as designed, it will fundamentally change the information environment in which homeowners insurance regulation operates. For an industry where the private market is visibly contracting in multiple states, where FAIR plan enrollment has grown 51% in nine years, and where peril-level losses are accelerating on climate-driven trends, the regulatory need for this data has never been clearer.