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“Regulatory Roundtable
Discussion”
Ken Creighton, ACAS, MAAA
Pennsylvania Insurance Department
CAS Ratemaking Seminar – March 13 - 14, 2006
REG-2
Overview

Rate Regulatory Environment

Hot Button Issues

Filing Do’s and Don’ts
Rate Regulatory Environment

Know the state’s Filing Requirements
In PA, the Requirements are available on the
Department’s website at:
http://www.ins.state.pa.us/ins/cwp/view.asp?a=1280&
Q=545457
 Alternatively, e-mail me at [email protected]
and I’ll send you the link.

Rate Regulatory Environment

Rate & Rule Filings
Filing Review (Waiting) Periods
 Filing Review Requirement
 High Profile Filings
 The Review Process
 Competitors’ Filings

Rate Regulatory Environment

Call or meet with the insurance department
In PA, we continue to welcome and encourage this
type of dialogue.
 We meet with 20 to 30 companies annually to
discuss either initial filing plans or plans to materially
revise existing rating structures prior to the
submission of a filing.

Hot Button Issues

Credit Scoring

PPA Territorial Rate Changes

Non-Traditional Rating Approaches
Hot Button Issues

Credit Scoring
In PA, we have not approved a personal lines rate
filing containing credit scoring.
 Underwriting guidelines/practices not reviewed nor
approved.
 Possible issue for new PA entrants (e.g. introducing
a countrywide program).

Hot Button Issues

PPA Territorial Rate Changes
Recent filings include Phila County changes < ROS
changes.
 Public comments from City of Phila Consumer
Advocate on some High Profile filings.
 Data by “territorial grouping” routinely requested in
Top 20 PPA filings.

Hot Button Issues

Non-Traditional Rating Approaches

Increase in Number of Tiers

Territories Vary by Coverage

Complex Rating Variables
Filing Do’s and Don’ts

Do:
Review the Filing Checklists.
 Highlight Changes in Cover Letter or Filing
Memorandum.
 Allow Department’s review period to be for the
review.
 Consider the policyholder’s perspective.

Filing Do’s and Don’ts

Don’t:
Request to have filing prioritized.
 Submit entire manual (or large portions) when only a
few items changed.
 Have conflicting information in filing (e.g. data
doesn’t reconcile; conflicting effective dates).

Thank You