Property & Casualty 2008 Compliance Conference

Overview of the Filings Made Easy (FME) Rule & Guide

Overview of the Overview Who’s Who TIC TAC TOE (legal stuff) SERFF What’s in a rule? Miscellaneous filings o Credit Model filings o Underwriting guideline filings

An Overview Session of the P&C Filing Process Tammy Lara, P&C Actuarial

With my filing?!? Who’s Who? And what do they do

Who has my filing? Property and Casualty Intake Unit Policy Form Filing Workers’ Compensation Rate Filing Personal and Commercial Lines Division Property & Casualty Actuarial Division

Legal stuff –TIC vs TAC – and how do I get my Toe in the door? Who makes it? What is each for? Where can you find it? Why do you need to know? What is recodification?

Legal stuff (cont.) – statutes and rules –TIC – Texas Insurance Code –TAC – Texas Administrative Code

Legal stuff (cont.) – statutes and rules –TIC – Texas Insurance Code –TAC – Texas Administrative Code

Legal stuff (cont.) – guides to help you through the maze –FME Guide –Checklists

SERFF –N–News: Credit Model filings are now accepted via SERFF!! (Note: CS filings must be submitted SEPARATE from other file types. It CANNOT be combined with rate or form filings)

–Interim SERFF Procedures – highlights All form filings fully processed through SERFF ½ of correspondence from Actuarial staff now issued through SERFF SERFF is optional – paper filings are still accepted

SERFF –Interim SERFF Procedures – Texas Quirks: When correspondence is issued from actuarial, expect two dispositions in SERFF. SERFF in Texas is an electronic transmission system and not the Department’s primary filing tracking system. The filing status in SERFF is not intended to be representative of the filing status in TDI’s tracking system. Rate only filings are acknowledged and closed in SERFF immediately by intake staff before forwarding to actuarial for review.

What if I use SERFF? -Public access / request for confidentiality Q. Why can’t I mark my submission as “Confidential” in SERFF? A. Texas does not utilize the public access feature of SERFF. As a result, how a submission is designated in SERFF is immaterial. Additionally, TIC § and § specifies: Each filing made, and any supporting information filed, under this chapter is open to public inspection as of the date of the filing. (§ is similar) Post conference update: see also

What if I use SERFF? -Delayed inquiries Q.My SERFF filing was closed a month ago, why am I getting an “after our initial review…” letter now? A.Current TDI procedure is for intake staff to close rate filings in SERFF system immediately upon receipt and acknowledgement. As noted in the “Note to Filer”, this does not mean that a filing has been reviewed by actuarial staff. Similarly, the Personal and Commercial Lines Division may have finished their review before actuarial begins their review.

What if I use SERFF? Rules, rates, forms and supporting information Q. Where does TDI prefer I place my attachments? A. As follows: “Form Schedule” Tab - Policy forms and endorsements “Rate/Rule Schedule” Tab – Rate manuals, Texas exception pages, etc. Please fill this section out completely and accurately. “Supporting Documentation” Tab – Cover letters, memorandum, side-by-sides, actuarial support, TDI exhibits, etc.

What’s in a Rule? Rating rules Form rules Underwriting guidelines –What are each of these? –Why does the distinction matter?

What’s in a Rule? Rules of thumb –Does it tell you how to calculate a rate? –Does it specify when a fee is applicable? –Does it tell you when to attach a form? –Does it describe coverage? –Does it specify who you will accept or reject for coverage? –Is it a combination?

What’s in a Rule? Examples –What kind of rules do the form technicians review? –What kind of rules do the actuaries review?

Miscellaneous Filings Credit Model Filings Underwriting Guideline Filings –Pertinent statutes –Pertinent rules –How to file/what to expect when you file –Why they can’t be combined with other filing types

Credit Model Filings Filing requirements apply to insurers writing personal insurance coverage as defined by TIC Chapter 559. FME Rule and Guide provide filing requirements for credit scoring models. Insurers using credit scores to underwrite and rate risks shall file their credit scoring models or other credit scoring processes with TDI.

Credit Model Filings Credit scoring model filings must be made separately from all other filings. Rates or rating factors based on credit scoring should be included in a rate filing. Credit scoring models are public information!

Underwriting Guidelines FME Rule and Guide provide underwriting guideline filing requirements for personal automobile and residential property insurance pursuant to TIC §38.002, and for workers’ compensation pursuant to TIC Chapter 2053 Subchapter A-1 (formerly Art. 5.55A). A complete copy is required at least once every 3 years (March 2010, March 2013). Update filings are accepted in the intervening years. Post conference clarification: A question was posed during the conference “If I already have a complete copy of my underwriting guidelines currently on file, do I need to re-file to comply?” Answer – no, the requirement is simply that a complete copy is required at least once every 3 years on or before March 1, beginning March 1, 2004.

Underwriting Guidelines Interim changes should be filed “not later than the 10th day” Underwriting guidelines for other lines are required only upon request, pursuant to TIC § Underwriting guidelines must be filed separately from other filings.

Questions?