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The core of the firm’s bearish thesis centers on a massive pool of routine, low-complexity insurance policies. The BofA analysts, Joshua Shanker, Joseph Tumillo, Cyril Onyango, and Fatima Keita, looked at just six major carriers catering to small businesses and personal lines: Travelers, Hartford, Progressive, Cincinnati Financial, Hanover, and Selective. From these six companies alone, BofA identified over $15 billion in commissions paid to independent agents in 2025 that largely skew toward low-complexity risks.
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