So, without getting to big of an industry impact this regulation has(assuming it survives any legal challenges as is), one of the sticking points for the new CA regulation is when the regulations were formally filed with the Secretary of State. I can’t actually find when that went live, does anyone know? It’s an important date as industry responses are due within 180 days as of the filing date.
Till all are one,
Epistemus
It was approved 10/17/22, and I have an effective date of 4/15/23… per work compliance person
Can’t let this pass without some quip about CA… so they’re already overloaded with the current workload and now the commissioner forces through a regulation to demand all insurers file within 180 days… don’t foresee any problems here
I mean, they have been overloaded for as long as I’ve been doing rate filings, so…
I have a double-digit rate increase that has been with the CA insurance department since November 2021. I think we’re getting close to the end, but don’t see the tunnel light yet.
Love it when the departments give themselves an extension…
cough WA
They asked for a good deal of new information in their latest objection (still no approval but I think we’re close)
- Ability to increase writings:
Please indicate if insurer will be able to expand or increase its writings for this program upon approval of this filing. We would like to know, in particular, the expansion to risks that have some form of exposure to wildfire. If insurer will not or cannot expand or increase its writings, please provide the reasons.
Honestly, they make us wait two years to get a rate increase and wonder why we might not want to increase our writings.
Yeah, they’re getting increasingly desperate for someone to write Wildfire. Reminds me of that meme with the guy putting the stick in his bicycle tire…
so, the ability to get your 2021 rate increase might depend on your willingness to increase writings in 2024.
I guess you could reply “we would like to know, in particular, the increase in response to requested rate action in response to growing exposure to wildfire. If regulator will not or cannot speed its response to requested rate changes, please provide the reasons.”
there are states and LOBs I can understand why companies avoid.
Please indicate if insurer will be able to expand or increase its writings for this program upon approval of this filing. We would like to know, in particular, the expansion to risks that have some form of exposure to wildfire. If insurer will not or cannot expand or increase its writings, please provide the reasons.
“Our ability to increase our exposure in the state is currently constrained by the statutory requirement that we charge rates that are not inadequate, and the capacity needs implied by our exposure to catastrophic risks and associated prudent risk management.”
Of course, back when I was doing rate filings, I was obliged to let our filing folks tone down some of my snottier suggested responses…
I think you and I probably have similar levels of potential snarkiness.
One time a rookie analyst at a midwest state improperly objected about something which was actuarially incorrect. I told him why he was in the wrong and insisted he set up a meeting with his supervisor (because I couldn’t believe the state would use this metric to judge rate adequacy). He immediately approved my filing.
Now that is a rare exception. I’ve never tried anything like that but his complaint was so actuarially egregious I felt the need to take it next level.
In all seriousness, I think that if I were doing rate filings and saw that as a question in an objection, I’d grab a handler from our filings team and get on the phone with the analyst, to respond verbally under the premise that strategic decisions like that are not ones we want publicly accessible to our competitors.
Then as part of that conversation, I’d try to be armed with indications using their math for what the remaining need would be and whatever shareable thoughts product management was having.
I do miss my days of doing pricing/product work…but I do NOT miss doing personal lines. If I ever rotate back over to pricing/product work, I’ll probably try for a large account or E&S product unless I have minions to do filings for me.