June 18, 2008
Donald S. Clark, Esq.
One State Farm Plaza, A-3
Bloomington, IL 61710-0001
Federal Trade Commission/Office of the Secretary
Room H-135 (Annex C)
Gregg R. Mecherle, CPCU, CLU
600 Pennsylvania Avenue N.W.
Washington DC 20580
Phone: (309) 766-1130
Fax: (309) 766-5850
Re: Credit-based Insurance Score – Homeowners Insurance – P044804
Dear Mr. Clark:
State Farm Mutual Automobile Insurance Company and its various subsidiaries and affiliates
(collectively, “State Farm”) thank the Federal Trade Commission (“FTC”) for the opportunity to
comment on the FTC’s proposed Order to File a Special Report (“Order”) under Section 6(b) of the
Federal Trade Commission Act (“FTC Act”).
State Farm is a mutual insurance company, meaning that it is not owned by stockholders, and its Board of
Directors is elected by its policyholders. State Farm companies offer financial services, including auto
and homeowner’s insurance, to consumers through a network of agents. State Farm companies insure
more cars and homes than any other insurer in the United States. State Farm’s 17,000 agents and 67,000
employees serve over 77 million auto, fire, life and health policies in the United States and Canada.
Section 215 of the Fair and Accurate Credit Transactions Act of 2003 (“FACT Act”) requires that the
FTC study the use of credit-based insurance scores in connection with property and casualty insurance.
The FTC is fulfilling this requirement by preparing two separate studies: (1) a study of the use of credit-
based insurance scores in connection with auto insurance (the “Auto Study”), and (2) a study of the use of
credit-based insurance scores in connection with homeowner’s insurance (the “Homeowners Study”).
The Auto Study was published last summer, and the FTC is in the process of conducting the Homeowners
On May 19, the