The Texas Department of Insurance is seeking comments on a plan to eliminate the manual rule filing type for property and casualty insurance. TDI will still require insurers to file all information that is currently included in manual rule filings, but insurers will instead file the appropriate information in two filing categories instead of three: either form and endorsement filings or rate filings.
The filing requirements for forms and endorsements require filers to provide an explanation of the policy forms and endorsements and how they will be used. Insurers often include this information in their manual rule filings.
The filing requirements for rate filings require filers to provide supplementary rating information, which Insurance Code §2251.002(7) defines, in part, as any manual, rating schedule, plan of rules, rating rules, classification systems, territory codes and descriptions, rating plans, and other similar information used by the insurer to determine the applicable premium for an insured. The information insurers submit in manual rule filings often duplicate the supplementary rating information included in their rate filings.
Eliminating the manual rule filing type would reduce the number of filings insurers make but not the information insurers submit. TDI anticipates that insurers would file all manual pages with their rate filings after the effective date of this change while still providing information about the use of forms and endorsements with their form filings.
TDI would allow insurers to reference the content of previously filed manual rule filings even though the filing that contains the reference is not a manual rule filing.
Comments on the following will help TDI make this change:
- How much lead time insurers need before this change goes into effect.
- What types of guidance TDI should provide to insurers.
- Any other relevant comments.
Please email your comments by September 14, 2017, to PCActuarial@tdi.texas.gov.
If you have any questions, please contact J'ne Byckovski, Director and Chief Actuary, Property and Casualty Actuarial Office, by phone at 512-676-6700 or by email at PCActuarial@tdi.texas.gov.