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<s>[INST]State of Alaska pet insurance regulatory filing objection: The objection letter is pending industry response. The objection was submitted on 12/16/2021 and a response is expected by 01/17/2022. The objection raises concerns about the filing's compliance with AS 21.39 requirements and the waiting period. It requests a new effective date if necessary and asks for identification of any changes to the filing. Additionally, it asks for clarification on the fees and expenses included in the Taxes, Licenses, & Fees expense provision.[/INST] The response letter has been submitted to the state on 01/13/2022. It acknowledges the objection letter dated 12/16/2021 and mentions that a post-submission update has been sent to amend the effective dates of the filing. In response to the concerns raised, the company has revised the Taxes, Licenses, and fees provision from 2.8% to 2.7%, resulting in a revised indication of +6.3%. Revised indication exhibits are provided in the attached file AK Objections 2021.12.16.pdf. The proposed base rates have also changed, and the revised files AK SEP 20220421.pdf and AK SEP 20220421Redline.pdf are attached. The response addresses the objection 1 and applies to various supporting documents. The tracking numbers and relevant details are provided. The response concludes by thanking for the continued review of the filing.</s> |
<s>[INST]State of Alaska pet insurance regulatory filing objection: The objection letter is pending industry response. The objection was submitted on 11/16/2021 and a response is required by 12/17/2021. The objection raises concerns about the adequacy of support provided for the director to determine if the filing meets the requirements of AS 21.39. It also questions the compliance of the proposed effective date with the waiting period requirement. Additionally, the objection requests the identification of any changes to the filing and the provision of revised rate level impacts. Objection 1 - The objection requests the upload of a copy of the circular being referenced for the miscellaneous tax of 0.34%. Conclusion: The objection letter concludes without further information.[/INST] The response letter was submitted to the state on 12/14/2021. It addresses the concerns raised in the objection letter. Response 1 - The response explains that while the company does not subscribe to the captioned circular, it received information about the provision from a reliable source. The company examined its Taxes, Licenses, and Fees experience specific to Alaska and selected a provision of 2.8% instead of the originally filed provision of 3.04%. Revised indication exhibits and proposed base rates are provided in the attached files. Related Objection 1 - The response acknowledges the request to upload a copy of the circular for the miscellaneous tax of 0.34%. However, the company states that it is unable to provide the circular.</s> |
<s>[INST]State of Alaska pet insurance regulatory filing objection: Objection 1: Please provide Exhibit 10 for Cat and Dog individually instead of combined. Objection 2: In response to Item 1.2.(a), please describe the miscellaneous tax of 0.34%. Objection 3: Provide a histogram of policyholder impacts and describe policy characteristics receiving impacts at or near the largest rate increase and decrease. Objection 4: Please provide additional information on the multivariate model used, including data description, validation methods, and interpretive explanation.[/INST] Thank you for your objection letter dated 10/21/2021. Here are our responses to your concerns: Response 1: Please refer to the attached exhibit AK Objections 2021.10.21 Item 1.pdf. Response 2: The Company references circular AS-CM-2020-002 as the source for the miscellaneous tax provision. Response 3: i) Please see Page 1 of the attached exhibit AK Objections 2021.10.21 Item 3.pdf for a histogram of policyholder impacts. ii) Page 2 of the same exhibit shows the policy characteristics driving the +106.2% rate increase, with the Breed Group being the main factor. iii) Page 2 also shows the policy characteristics driving the -77.1% rate decrease, with the Breed Group being the main factor. Response 4: (1) The dataset used in the model was split into modeling, training, and holdout datasets with a 2:1 ratio. Please refer to Exhibit 1 of the attached file AK Objections 2021.10.21 Item 4.pdf for a distribution of policyholders by state. Exhibit 2 provides a list of variables used in the model. (2) Pearson correlation coefficients were reviewed, and stability of coefficients was tested. Please refer to Exhibit 3 for a Pearson Correlation Matrix and Exhibit 4 for observed vs. fitted pure premium charts. Thank you for your attention to this matter.</s> |
<s>[INST]State of Alaska pet insurance regulatory filing objection: The objection letter is pending industry response. The objection was submitted on 09/14/2021 and a response is expected by 10/15/2021. The objection raises concerns about the adequacy of support provided for the director to determine if the filing meets the requirements of AS 21.39. It also questions the compliance with the waiting period requirement and requests clarification on various aspects of the filing.[/INST] Thank you for your objection letter dated 09/14/2021. We have prepared a response document and attached exhibits to address your concerns. The response provides justifications and further details on the historical loss trend selection, expenses, co-pay option factors, inclusion of Canada in the Cat Country Territory Level, previous GLM approval, and the changes made in the GLM analysis. Please refer to the attached response document and exhibits for more information.</s> |
<s>[INST]State of Alaska pet insurance regulatory filing objection: Please provide justification for selecting a trend of 7%, which is higher than all of the presented regressions within the trend exhibit. AS 21.39.030 AS 21.39.040(d)[/INST] In this filing, we propose a non-wellness historical annual trend of 6.3%, based on the 60-month regression results found in the support document, Exhibit - Trend Development - Alaska - 20220803.pdf. The rate indications are developed using the same 60 months of data. Considering the current rate of inflation, we anticipate a higher prospective trend than what we have observed historically. Therefore, we have chosen a prospective trend of 7.8%. We have submitted an additional support document, Exhibit - Veterinary Services CPU-U.pdf, which demonstrates the increase in Veterinary Services costs based on the Consumer Price Index for Urban areas. Recent year-over-year comparisons show a substantial rise, with single-month comparisons indicating up to a 9.8% increase compared to the previous year. To account for this increase in base costs, we have selected a prospective trend of 7.8%, aligning with the year-over-year values observed in 2022. By combining a historical trend of 6.3% until 3/1/2022 and a prospective trend of 7.8% from 3/1/2022 to the midpoint of the experience period, 1/1/2024, we arrive at a combined, single annual trend of 7.0%.</s> |
<s>[INST]State of Alaska pet insurance regulatory filing objection: Please provide underlying expense and profit exhibits to support the expected loss ratio used in the rate level indication. If necessary, explain any provisions selected based on judgment.[/INST] Refer to the attached file titled "Figo Expense and Profit Support.pdf" which includes the expense and profit exhibits supporting the expected loss ratio of 58.1%.</s> |
<s>[INST]State of Alaska pet insurance regulatory filing objection: Please explain how the Proposed State Factor change on Page 6 of 8 in the Rate Impact exhibits is developed. If there is quantitative support, please provide the exhibits.[/INST] The proposed change to the state factor is determined to meet the overall credibility adjusted statewide indicated change after making individual proposed factor changes. This approach allows breed factors, plan factors, age factors, and others to align with a nationwide schedule while allowing each state's rates to adjust based on their specific experience. Page 7 of the experience exhibit demonstrates that the overall proposed change calculated on page 6 aligns with the credibility adjusted rate level indicator.</s> |
<s>[INST]State of Alaska pet insurance regulatory filing objection: Experience has improved in 2021 and 2022 on both a countrywide and Alaska basis. Please document any underlying drivers of the improved experience.[/INST] Please note that the nationwide and Alaska experience provided on page 1 represents the actual experience under the issued rates for both Independence American Insurance Company (IAIC) and the prior carrier. The rate adjustments on pages 2 through 7 are based on Adjusted Premium, where all prior experience is evaluated under the currently approved rate structure. We are submitting an additional exhibit, Exhibit - Alaska Adjusted Experience - 20220926.pdf, which includes the experience adjusted to the current rates and claims trended to 1/1/2024. The nationwide driver of the improved experience is the rate adequacy associated with the policy, as the experience is much more consistent when viewed on the same rate level. However, Alaska experience, especially in older years, is limited and not very credible. Additionally, the statewide data for calendar year 2022 only includes the first three months of experience, which can skew the results. Our goal is to achieve a 1.00 Actual to Expected Loss Ratio both nationwide and in each state by analyzing the experience adjusted to the currently approved rates.</s> |
<s>[INST]State of Alaska pet insurance regulatory filing objection: The experience has improved in 2021 and 2022 on both a countrywide and Alaska basis. Please explain whether the more recent experience periods are better predictors of the prospective loss experience.[/INST] As mentioned in Objection 4, the experience improvement in 2021 and 2022 is attributed to the rate adequacy of the approved rates at IAIC and the prior carrier. When adjusting all experience to the currently approved rates, the experience for each year becomes more stable nationwide. Therefore, we believe that the experience from 2017 to 2020 is still a valid predictor of prospective loss experience and should be analyzed alongside the experience from 2021 and 2022. Although 2021 and 2022 represent a larger portion of the time frame and exposures, the overall credibility of the experience in Alaska is not very high. Additionally, due to inflation and increasing veterinary costs, we anticipate that the prospective loss experience may increase compared to prior years. We have researched rising costs in the veterinary industry, as shown in the attached file Exhibit Veterinary Services CPI-U.pdf, which demonstrates substantial increases in claims cost trends in 2022.</s> |
<s>[INST]State of Alaska pet insurance regulatory filing objection: Please provide documentation on the general characteristics of the group of members receiving the highest premium increases within the proposed rate distribution.[/INST] The pets experiencing the largest premium increase are mostly dogs, with a relatively equal distribution between males and females. These policies primarily have an annual limit of $10,000 or unlimited, a $500 deductible, and 100% coinsurance. The majority of these policies are for mixed breed pets. Age is not a factor in this filing as there are no proposed changes to age factors.</s> |
<s>[INST]State of Alaska pet insurance regulatory filing objection: The company is requesting its second rate increase of 10% or more within a year. Please provide a summary of other actions being taken by the company, in addition to rate revision filings, to address overall profitability.[/INST] Rate filing updates are a significant part of addressing overall profitability as they ensure that premiums charged are sufficient for the coverage provided and account for growing claims costs. The company conducts regular reviews of the product, monitors claims patterns, demographic changes, and emerging experience to ensure the product meets customer needs, remains competitive in pricing and coverage, and is appropriately priced. In the previous rate filing (SERFF #IADC-133064622), we were limited to a +10.0% rate increase by the department, despite an indication of +26.2% based on credibility weighting. As a result, we are now requesting an increase of +11.1% to achieve rate adequacy. It's important to note that our previous filing had an intended effective date of 1/1/2022 but was approved with an effective date of 6/1/2022. Our intention is to return to annual rate filings to maintain rate adequacy.</s> |
<s>[INST]State of Alaska pet insurance regulatory filing objection: Please provide a specific explanation of what is driving the indicated rate need, including factors such as utilization, frequency, severity, specific underperforming segments, and other trends.[/INST] The case mix change, adverse loss experience in Alaska, limited rate increase in our prior filing, and the impact of trend discussed in objection 1 are driving the indicated rate need. In our previous filing, the proposed rate increase was limited to +10.0% by the department, despite a credibility weighted rate level indication of +26.2%. This limitation has influenced the rate indication in this filing. We have included a file titled "Trend Analytic_Figo.pdf" which provides details on the frequency, severity, and case mix contributions to trend, highlighting case mix change as a primary driver.</s> |
<s>[INST]State of Alaska pet insurance regulatory filing objection: Objection 9 - Alaska - New Only Rate Sheets, null (Rate) - What are the differences between pages 13 and 14? How do the rules differentiate? AS 21.39.040[/INST] Page 13 and Page 14 of the rate manual provide plan factors based on the adjudication method for the policy. The adjudication method is explained in section II.E of the Underwriting Rules and Guidelines on page 2. Page 13 presents factors for combinations of deductible and coinsurance under a Coinsurance First adjudication, where the member pays the coinsurance portion of cost sharing first. Page 14 provides the same combination of factors, but for policies with a Deductible First adjudication, where the deductible is paid before coinsurance.</s> |
<s>[INST]State of Alaska pet insurance regulatory filing objection: Objection 1 - Regarding the response. Comments: The marked copy in this filing has the same edition date as the final copy, which is 9/21/2022. A clearly marked copy showing any changes must be attached to the Marked Copy section of the Supporting Documentation tab, with new material underlined and deleted material stricken through.[/INST] Response 1 - Please refer to the updated marked copy. Comments: The marked copy attached shows changes to the prior authorized copy in filing IADC-132956232, which has an edition date of 08/19/2021. The marked copy in this filing has the same edition date as the final copy, which is 9/21/2022.</s> |
<s>[INST]State of Alaska pet insurance regulatory filing objection: The marked copy in this filing has the same edition date as the final copy, which is 9/21/2022, but it should show changes from the prior authorized copy in filing IADC-132956232 with an edition date of 08/19/2021. The marked copy must clearly indicate new material with underlining and deleted material with a line stricken through it, as required by 3 AAC 31.210(h) and 3 AAC 31.299(1).[/INST] Please refer to the attached exhibit "Expense and Profit Support.pdf" for the requested information.</s> |
<s>[INST]State of Alaska pet insurance regulatory filing objection: Please document any distributional shifts that are causing the negative premium trend from late 2020 to early 2022.[/INST] The negative premium trend is a result of a shift in the mix of business towards lower cost breeds, younger age at enrollment, and higher deductibles.</s> |
<s>[INST]State of Alaska pet insurance regulatory filing objection: Please provide documentation for the underlying causes of the severity trend in pet insurance, which consistently remains near +15% based on the regressions provided by the Company. Refer to AS 21.39.030 and AS 21.39.040(d).[/INST] The severity trend in pet insurance, consistently near +15%, is primarily driven by veterinary inflation trends and improved access to higher quality care (e.g., more MRIs and fewer X-rays). Nationally, the current veterinary CPI stands at 10.0%, and we anticipate our forward-looking PPPM loss trends to be comparable.</s> |
<s>[INST]State of Alaska pet insurance regulatory filing objection: Please provide documentation of the quantitative support or professional judgment used to select a 5.0% profit & contingency factor, as required by AS 21.39.030 and AS 21.39.040(d).[/INST] Due to the nature of pet insurance being a short tail line of business with limited opportunity for investment income on held reserves, we have chosen to utilize the traditionally accepted underwriting profit provision of 5%.</s> |
<s>[INST]State of Alaska pet insurance regulatory filing objection: Regarding the Dog Age curves, please provide documentation on how the Company selected factors. It seems that the Company relied more on the indicated relativity rather than the credibility adjusted factor, while also making corrections for reversals. Please clarify.[/INST] Trupanion has made updates to the credibility adjusted factor formula, adjusting the column titled Claims relativity key to .9 with the column titled Current Factor. For older dogs, Trupanion placed more weight on the indicated relativity, as it aligns with our 100% credible Book of Business factors.</s> |
<s>[INST]State of Alaska pet insurance regulatory filing objection: Please review the submitted Rules and Rates along with the Marked Copy. We are unsure if they are filed correctly based on the current approved program. Specifically, the filed rules include the Landspath Food Program Factor, which is not part of the current program or included in this filing. Please advise or submit a Marked Copy of Rules and Rates that align with this program and filing. AS 21.39.040(d)[/INST] We have respectfully removed the Landspath Food Program Factor from the Rules and Rates and Marked Copy. An updated Rules and Rates, along with the Marked Copy, will be submitted to align with this program and filing.</s> |
<s>[INST]State of Alaska pet insurance regulatory filing objection: Which table clearly identifies the associated breed with the number? The current table is unclear. Additionally, will cats remain unchanged in the rating? Is there a way to differentiate between felines and canines?[/INST] Trupanion unintentionally omitted the breed ID, age ID, and geo ID tables. We have resubmitted URM Table 1 Pet Factor AK Key to include the associated breed with species and ID, associated Geo Region with Zip code, associated age at enrollment with Age ID, and Gender with Gender ID. Cats will remain unchanged in the rating. The Breed ID table in URM Table 1 Pet Factor AK Key can be used to identify species.</s> |
<s>[INST]State of Alaska pet insurance regulatory filing objection: The objection letter is pending industry response. Adequate support has not been provided to determine if the filing meets the requirements of AS 21.39. The waiting period has not commenced, and the proposed effective date may not comply with the waiting period requirement. If necessary, a new effective date must be requested in the response, allowing for a 30-day waiting period. Any changes to the filing must be identified, and revised rate level impacts must be provided if applicable. Failure to respond or request an extension within 30 days will result in disapproval of the filing. Late responses must be complete resubmissions that address the questions and comments and reference the tracking number. The response must be received before 3:00 pm Alaska time on the due date, or the next working day if received after 3:00 pm or on a weekend or state holiday. Objection 1: Rate and form filings become public information after they become effective. Certain information can be designated as confidential if it meets the criteria of being a trade secret or proprietary business information. To request confidentiality, a legal argument must be provided directly to the director, clearly identifying the information and explaining why it should be considered confidential.[/INST] We understand that rate and form filings become public information after they become effective. We will not be requesting confidentiality for this filing. Thank you for your continued review. Related Objection 1: Rate and form filings become public information after they become effective. Confidentiality can be requested for certain types of information that meet the criteria of being a trade secret or proprietary business information. To pursue this option, a legal argument must be provided directly to the director, clearly identifying the information and explaining why it should be considered confidential. Conclusion: Thank you for your continued review of this filing.</s> |
<s>[INST]State of Alaska pet insurance regulatory filing objection: Objection 1 - Certification Form (Supporting Document) Comments: The division has issued guidance to insurers, suspending the file and use provisions under AS 21.39.220 and AS 21.42.125 for 15 months. File and Use filings will be treated as Prior Approval as per Regulatory Order R22-02. The filing method should be revised to Prior Approval via post submission update. This order is effective from May 1, 2022, to August 1, 2023. Thank you for your understanding.[/INST] A response to the objection dated 10-25-22 is being submitted.</s> |
<s>[INST]State of Alaska pet insurance regulatory filing objection: The objection states that the language in the policy regarding voiding coverage for fraud and misrepresentation violates Alaska Statutes 21.42.110 and 21.36.220.[/INST] The provision in both policies has been revised to replace all references to voiding coverage with canceling the coverage. This addresses the concern raised regarding the violation of Alaska Statutes 21.42.110 and 21.36.220.</s> |
<s>[INST]State of Alaska pet insurance regulatory filing objection: The objection states that the mentioned forms, which include promotional items, partner promotional items, prizes, contests, sweepstakes, or raffles, special promotions for referrals, special promotions for partner referrals, value-added services, partner value-added services, non-insurance services, and partner non-insurance services, are considered sources of rebating and are not compliant with Alaska Statute 21.36.120(a).[/INST] In response to the objection, we have reviewed Alaska Statute Ann. § 21.36.120 and request that the objection be reconsidered. We believe that the rebating prohibition applies only to promotional items or valuable considerations that are not specified in the filed policy. We have included language regarding such promotions and considerations in the filed policy to comply with Alaska law. It is important to note that Alaska law applies equally to agents and producers, and we have added promotions and considerations to be paid by them in the policy language to ensure compliance. We assure you that all promotions and considerations will be applied equally to similarly situated consumers. We respectfully request to maintain the language in the provisions mentioned in the objection. Additionally, not all provisions mentioned in the objection automatically qualify as rebating. Alaska Bulletin 2002-01 allows for compensation for referrals under certain conditions. We acknowledge that simply including an item considered to be a rebate or special favor in the policy language does not automatically ensure compliance with Alaska law. We believe that our policy provisions and underwriting guidelines do not constitute unfair discrimination between insureds, as they are specified in our filings and apply equally to all similarly situated consumers. This is supported by Alaska Bulletin 2015-12, which requires disclosure and documentation of considerations affecting price differentials in rate filings. We understand the discretion of the Insurance Department and are not proposing services without limitation. We are requesting the ability to provide promotions, benefit considerations, and services as specified in the applicable filing with the director, in accordance with § 21.36.120(c).</s> |
<s>[INST]State of Alaska pet insurance regulatory filing objection: Please provide a list of the associated groups eligible for Group Membership coverage or rate discounts. This will ensure fair discrimination in applying these discounts, as required by AS 21.36.190(a-f).[/INST] Refer to our response objection #2 dated 11/02/2022 in the corresponding rate filing IAIC-133395340.</s> |
<s>[INST]State of Alaska pet insurance regulatory filing objection: The language in the policy regarding the assignment and payment of claims does not comply with Regulation 3 AAC 26.070(a)(2), which requires prompt payment of undisputed portions of a claim within 30 working days.[/INST] Thank you for your comments. After a thorough review of Regulation 3 AAC 26.070, we have made modifications to our Right to Collect Information, Claims Under Investigation, and Assignment and Payment of Claims provisions to ensure alignment with the intent of the regulation.</s> |
<s>[INST]State of Alaska pet insurance regulatory filing objection: On page 2, Taxes, Licenses, & Fees are listed as 5.1%. Please specify the fees or expenses included in addition to Alaska's 2.7% premium tax.[/INST] The 5.1% on page two includes the state premium tax of 2.7% as well as state filing fees, certificate of authority fees, and state assessments. These amounts are derived from statutory filings and are based on company-wide data. It's important to note that the premiums in the filing are calculated using a nationwide average of 2.75% for premium taxes and fees.</s> |
<s>[INST]State of Alaska pet insurance regulatory filing objection: Please ensure that the Indicated Rate Change Percentage on the Rate/Rule Schedule matches the submitted filing support.[/INST] We will update the Rate/Rule Schedule to align with the filing support. Related Objection: Please ensure that the Indicated Rate Change Percentage on the Rate/Rule Schedule matches the submitted filing support. Changed Items: No changes were made to Form Schedule items, Rate/Rule Schedule items, or Supporting Documents.</s> |
<s>[INST]State of Alaska pet insurance regulatory filing objection: Objection 1: Regarding the response to... Comments: Please remove the sentence regarding Plus.[/INST] Response 1: The sentence regarding Plus has been removed. Please refer to the supporting document: AK Major Medical and Pet Wellness Plus Rider Filing Memo_updatedv2. Related Objection 1: Regarding the response to Objection #2, which states... Comments: Please remove the sentence: "We are requesting a rate change on the Plus level of coverage which is outlined within the Pet Wellness Rider form (VS-281)." AS 21.39.040(d) Changed Items: No Form Schedule items changed. No Rate/Rule Schedule items changed. Supporting Document Schedule Item Changes: Satisfied - Item: Explanatory Info - Rates Attachment(s): AK Major Medical and Pet Wellness Plus Rider Filing Memo_updatedv2.pdf</s> |
<s>[INST]State of Alaska pet insurance regulatory filing objection: Objection #2 states that a rate change is not being requested for the Plus level of coverage in this filing, only for the Major Medical plan. Please remove the sentence that requests a rate change for the Plus level of coverage outlined in the Pet Wellness Rider form (VS-281) to avoid confusion. AS 21.39.040(d)[/INST] We apologize for the oversight, but the exhibits were not initially uploaded with the filing as we had thought. They have now been attached for your review. Regarding Objections #3 and #4, please specify which filing contains the requested information and how the filing notes were amended according to the responses. Please submit exhibits 1-4 for review. AS 21.39.040(d) As per Alaska Statute 21.39.040, if a filing does not include the necessary information to support it and the director cannot determine if the filing meets the requirements of Alaska's rating laws, the insurer must provide the supporting information. Please refer to regulations 3 AAC 29.300(11) and 3 AAC 31.230 for the items that should be included in the supporting documentation.</s> |
<s>[INST]State of Alaska pet insurance regulatory filing objection: Please complete the Previous State Filing Number field on the Rate/Rule Schedule as required by regulations 3 AAC 31.210(h) and 3 AAC 31.225(a)(10).[/INST] The previous state filing number is NWPP-132697124. We will update the Rate/Rule Schedule accordingly.</s> |
<s>[INST]State of Alaska pet insurance regulatory filing objection: The objection states that a rate change is being requested for the Plus level of coverage outlined in the Pet Wellness Rider form (VS-281), but no rate changes are found in the marked copy of the manual. Please provide the location of these rate changes and the required supporting documentation as per AS 21.39.040 and regulations 3 AAC 29.300(11) and 3 AAC 31.230.[/INST] We apologize for the confusion. We are not requesting a rate change for the Plus level of coverage in this filing. Our rate change request only applies to our Major Medical plan.</s> |
<s>[INST]State of Alaska pet insurance regulatory filing objection: Please provide support for the change in the Base Rate, as required by AS 21.39.040(d), to demonstrate compliance with AS 21.39.030(a) and 3 AAC 29.250(c). Alaska Statute 21.39.040 states that when a filing is not accompanied by the information upon which the insurer supports the filing, and the director does not have sufficient information to determine whether the filing meets the requirements of Alaska's rating laws, the insurer shall be required to furnish the information upon which the insurer supports the filing. Please refer to regulations 3 AAC 29.300(11) and 3 AAC 31.230 for items that should be included as part of the supporting documentation.[/INST] The purpose of the Base Rate change is to offset the impact from the Age and Breed Factor adjustments. For this filing, a Base Rate change of -1.4% was applied to neutralize the positive impact caused by the Age and Breed Factors. Please refer to Supporting Exhibit 3 to see the stepwise rate impact from these factors.</s> |
<s>[INST]State of Alaska pet insurance regulatory filing objection: Please provide support for Age Rating and Breed Factors, as required by AS 21.39.040(d), to demonstrate compliance with AS 21.39.030(a) and 3 AAC 29.250(c). Alaska Statute 21.39.040 states that when a filing lacks the necessary information to determine compliance with Alaska's rating laws, the insurer must furnish the supporting information. Refer to regulations 3 AAC 29.300(11) and 3 AAC 31.230 for the required supporting documentation.[/INST] The support for the Age and Breed factors can be found in Supporting Exhibit 1 and 4. Additional details can be found in our Actuarial Memorandum and Indication Exhibits, which demonstrate compliance with Alaska's rating laws.</s> |
<s>[INST]State of Alaska pet insurance regulatory filing objection: Objection 1 - The offering of benefits such as gifts, sweepstakes, prizes, contests, and discounts may be considered a form of rebating.[/INST] Response 1 - We have addressed your objection by removing all related provisions from our underwriting rules and rating manual. While we revised our Special Promotions for Referrals provision, we did not remove it as referrals were not specifically mentioned in the objection. We believe that providing a nominal one-time gift card or promotional item for a referral is not considered rebating and is not prohibited under Alaska law. Alaska Statute § 21.27.370(c) allows compensation for referrals as long as it is a one-time payment of a nominal fixed amount and does not depend on the purchase of insurance. Our Special Promotions for Referrals language reflects this, stating that we may provide small rewards and incentives of nominal value for customer referrals or if the policyholder recommends someone to us. We believe our provision complies with Alaska law as the benefit for providing a referral is not contingent on insurance purchase, is of nominal value, and is not paid on a recurring basis. We respectfully request that you reconsider your objection in this regard.</s> |
<s>[INST]State of Alaska pet insurance regulatory filing objection: The objection states that when proposed rates and rules are based on those approved for another insurer, the filing should include supporting documentation to identify differences in coverages, underwriting selection, target markets, special services offered, and company operating expenses versus the competitors. It should also demonstrate how these differences are accounted for in the proposed rates, identify the filings in which the competitor material was approved in Alaska or attach relevant supporting documentation from filings approved in other states. Additionally, it should explain how trends have been accounted for since the competitor material was approved and any adjustments made for differences among filing jurisdictions. The objection also requests the attachment of referenced support from other IAIC program filings.[/INST] Please refer to the attached formal response letter and additional exhibits. Related Objection: The objection reiterates the need for supporting documentation when rates and rules are based on those approved for another insurer. It specifically mentions the Actuarial Memorandum and the Exhibit - Experience, which reference other IAIC program filings such as the United States Fire Insurance Company filing, the Trupanion filing, the Figo filing, and the Independence American Insurance Company Pets Best and Pet Partners filings. The objection requests the attachment of the referenced support from these other IAIC program filings. Changed Items: No changes to Form Schedule items or Rate/Rule Schedule items. SERFF Tracking #: IAIC-133395340 State Tracking #: IAIC-133395340 Company Tracking #: 2023 INDIVIDUAL PET RATES - AK State: Alaska Filing Company: Independence American Insurance Company TOI/Sub-TOI: 09.0 Inland Marine/09.0004 Pet Insurance Plans Product Name: 2023 Individual Pet - Rates Project Name/Number: SPOT/NEW PRODUCT FILING-2023 INDIVIDUAL 03/07/2023 11:44 PM Supporting Document Schedule Item Changes: - Explanatory Info - Rates: Satisfied - Attachment(s): Alaska - Actuarial Memorandum - 20221004.pdf, Alaska - Exhibit - Experience - 20221201.pdf, Alaska - Exhibit - Deviations.xlsx, Alaska - Exhibit - Deviations.pdf</s> |
<s>[INST]State of Alaska pet insurance regulatory filing objection: Objection 2 - Pages 33 and 34 introduce discounts for Association Groups, Affinity Group, and customers of Strategic Partners. Please provide a list of these associated groups who are eligible, as this will guide underwriters in applying these discounts in compliance with AS 21.36.190(a-f).[/INST] Attached is the response to the objection.</s> |
<s>[INST]State of Alaska pet insurance regulatory filing objection: Objection 3 - Page 34 discusses an Installment Fee. Fees related to premium payment transactions, such as late payment fees, insufficient funds fees, installment fees, and convenience fees, cannot be charged until they have been filed and approved under AS 21.39.041 or AS 21.39.220. Refer to 3 AAC 26.885 for more information.[/INST] Response - 20221102.pdf</s> |
<s>[INST]State of Alaska pet insurance regulatory filing objection: Objection 4 states that pages 35 and 36 list non-compliant promotional items and services. Requesting a review and revision. Alaska Statute 21.36.120(a) prohibits insurers from offering inducements or valuable considerations not specified in the policy, unless provided for in an applicable filing with the director. It is also noted that including such items in the policy language does not automatically ensure compliance with Alaska law, including AS 21.36.090(c) and AS 21.36.120(c).[/INST] Response 2 states that there is currently no specific list of entities that qualify for the mentioned discounts, as it is a new program that has not yet launched. However, once these entities are determined, they will be included in future rating manuals. Related Objection 2 requests a list of eligible associated groups for discounts introduced on pages 33 and 34. This will provide clear guidance to underwriters for fair discrimination in accordance with AS 21.36.190(a-f).</s> |
<s>[INST]State of Alaska pet insurance regulatory filing objection: This filing is currently pending industry response. It has been disapproved under AS 21.39.041 and will not take effect unless the division approves it based on additional information provided. The response must address any changes to the filing and provide revised rate level impacts if necessary. A response is required within 30 days from the date of this letter, with the option to request a 15-day extension in writing. Failure to respond within the specified time frame will be considered a request to withdraw the filing. If a response is received after 3:00 pm Alaska time or on a weekend or state holiday, the receipt date will be the next working day. Objection 1: The explanatory memo for the Pet Health program revision states that Westchester Fire Insurance Company is filing a revision and includes a marked copy. Please review and revise the Rate Action field from "new" to "replacement" within the Rate/Rule Schedule tab and include the Previous State Filing Number as required by AS 21.39.040(d).[/INST] Thank you for your objection letter dated 02/14/2023. Please see the changes below. Related Objection 1: Applies to the Explanatory Info - Rates (Supporting Document). The memo states that Westchester Fire Insurance Company is filing a revision to its Pet Health program and includes a marked copy. Please review and revise the Rate Action field from "new" to "replacement" within the Rate/Rule Schedule tab and include the Previous State Filing Number as required by AS 21.39.040(d). Changed Items: No Form Schedule items changed. Rate Schedule Item Changes: Item No. 1 - State Exception PagesWFIC - 2022 AK Pgs 1-13 Rule # or Page #: Replacement Previous State Filing Number: ACEH-133040565 Conclusion: Thank you for your continued review of this filing.</s> |
<s>[INST]State of Alaska pet insurance regulatory filing objection: The objection letter is pending industry response. Adequate support has not been provided to determine if the filing meets the requirements of AS 21.39. The waiting period has not commenced, and the proposed effective date may not comply with the waiting period requirement. If necessary, a new effective date must be requested in the response, allowing for a 30-day waiting period. Any changes to the filing must be identified, and revised rate level impacts must be provided. Failure to respond or request an extension within 30 days will result in disapproval of the filing. Late responses must be a complete resubmission that addresses the questions and comments and references the tracking number. The response must be received before 3:00 pm Alaska time on the due date, or the next working day if received after 3:00 pm or on a weekend or state holiday. Objection 1: Since there are no policies or experience for this filing, were the pricing trend assumptions based on individual programs to increase the medical base rate by 10%? If so, please provide the filing numbers.[/INST] The pricing trend assumption of 10% is based on the experience of the following individual program: Program - PPI. Please refer to the attached file (Trend Exhibit 2022-12.pdf) for details. The filing number for the program is IAIC-133465505.</s> |
<s>[INST]State of Alaska pet insurance regulatory filing objection: The division has suspended the file and use provisions under AS 21.39.220 and AS 21.42.125 for 15 months, treating File and Use filings as Prior Approval if necessary. Regulatory Order R22-02 designates this filing as Prior Approval, effective May 1, 2022, and expiring on August 1, 2023. Please update the filing method to Prior Approval via post submission update.[/INST] A post submission update has been submitted to change the filing method to prior approval.</s> |
<s>[INST]State of Alaska pet insurance regulatory filing objection: The marked copy does not show any underlined or stricken through material. Please review and resubmit a clearly marked copy that clearly indicates changes to the form, rate, or rule filing.[/INST] We apologize for the oversight. The marked copy has been removed from the Supporting Documentation tab.</s> |
<s>[INST]State of Alaska pet insurance regulatory filing objection: The objection letter is pending industry response. The objection was submitted on 01/20/2023 and a response is expected by 02/19/2023. The objection raises concerns about the adequacy of support provided for the director to determine if the filing meets the requirements of AS 21.39. It also questions the compliance of the proposed effective date with the waiting period requirement. The response is expected to address any changes to the filing and provide revised rate level impacts if necessary. Failure to respond within 30 days will result in disapproval of the filing. Objection 1: The objection requests a review and revision of the Previous State Filing Number field on the Rate/Rule Schedule. It also asks for an updated marked copy showing changes to the form, rate, or rule filing.[/INST] The response letter has been submitted to the state. The previous state filing number has been amended on the Rate/Rule Schedule. An updated marked copy of the Rate/Rule Manual has been provided in response to the objection and uploaded to the Supporting Documentation tab.</s> |
<s>[INST]State of Alaska pet insurance regulatory filing objection: The objection letter is pending industry response. The objection was submitted on 12/16/2022 and a response is expected by 01/15/2023. The objection raises concerns about the adequacy of support provided for the director to determine if the filing meets the requirements of AS 21.39. It also mentions the waiting period requirement and the need for a new effective date if necessary. The response must identify any changes to the filing and provide revised rate level impacts if applicable. Failure to respond within 30 days will result in disapproval of the filing. Objection 1: The objection requests completion of the Corresponding Filing Tracking Number field to reference the corresponding filings. It cites specific regulations and instructions regarding cross-referencing requirements. Objection 2: The objection points out that the marked copy does not show any underlined or stricken through material. It requests a clearly marked copy that highlights changes to the filing.[/INST] The response letter has been submitted to the state on 01/09/2023. Response 1: The corresponding tracking number (USAI-1334633830) has been added via a post-submission update. Related Objection 1: The response acknowledges the need to complete the Corresponding Filing Tracking Number field and provides instructions for doing so. Response 2: The response apologizes for the oversight and states that a corrected version of the markup document has been uploaded. A revised version of the finalized rate/rule manual has also been added due to a missing item. Related Objection 2: The response acknowledges the issue with the marked copy and assures that a corrected version has been submitted. Changed Items: No changes have been made to the form schedule, rate/rule schedule, or supporting documents. SERFF Tracking #: USAI-133463384 State Tracking #: USAI-133463384 Company Tracking #: State: Alaska Filing Company: United States Fire Insurance Company TOI/Sub-TOI: 09.0 Inland Marine/09.0004 Pet Insurance Plans Product Name: PET - V4.5 Project Name/Number: Conclusion: The response concludes without further details.</s> |
<s>[INST]State of Alaska pet insurance regulatory filing objection: This filing is disapproved under AS 21.42.123 and AS 21.42.130. It will only take effect if the division approves it based on additional information provided by the company. A response addressing the raised issues must be submitted within 30 days from the date of this letter. If more time is needed, a written request for a 15-day extension can be made before the 30-day response period expires. The response must be received by 3:00pm Alaska time on the due date. If received after this time, it must be a complete resubmission of the filing, addressing the questions and comments and referencing the tracking number. If received after 3:00 pm Alaska time or on a weekend or state holiday, the receipt date is the next working day. Objection 1: The filing method indicated for the Certification Form does not match the Prior Approval method being used. The "File and Use" Compliance Certificate is only required for form filings under the F&U filing method. Objection 2: The amended definition of "Covered Expenses" does not comply with Alaska Statute. The previous objection letter addressed this issue, stating that the restriction results in excessive premiums for insureds with overlapping coverage, in violation of Alaska Statute 21.39.030(a)(1). Please revise.[/INST] Response 1: Acknowledged. Response 2: In response to this objection, the company has amended the definition of Covered Expenses in each of the forms to remove the language regarding costs covered by other insurance or benefit programs. Updated versions of the endorsements have been submitted with this response.</s> |
<s>[INST]State of Alaska pet insurance regulatory filing objection: The final copy was not filed under the Rate/Rule Schedule. Please review and revise.[/INST] The revised final copy of the Pet Manual is included with this response.</s> |
<s>[INST]State of Alaska pet insurance regulatory filing objection: The objection states that when proposed rates and rules are based on those approved for another insurer, the filing should include supporting documentation to identify differences in coverages, underwriting selection, target markets, special services offered, and company operating expenses versus the competitors. It should also demonstrate how these differences are accounted for in the proposed rates and provide information on the filings in which the competitor material was approved in Alaska or attach relevant supporting exhibits from filings approved in other states. Additionally, it should explain how trends have been accounted for since the time the material was approved for the competitors and any adjustments made to account for differences among filing jurisdictions.[/INST] The injury only base rates and Breed & Age factors were developed from a prior approved filing (META-132852740). The base rate relativity of Injury Only to Illness & Injury was 0.24, consistent with the current filing. Please refer to page 6 of 9 of the Rate Increase Support Exhibit for further information on age development. Due to an error in trending, the base rates have been updated. The prior rates were incorrectly trended to 7/1/2023. The updated Rate Increase Support Exhibit reflects the correct rates.</s> |
<s>[INST]State of Alaska pet insurance regulatory filing objection: The selected 2.1% for Taxes, Licenses, and Fees is not appropriate considering Alaska's Premium Tax is 2.7% per AS 21.09.210(b)(1).[/INST] Thank you for bringing this to our attention. We have updated the actuarial memo to reflect the correct rate of 2.7% instead of 2.1%.</s> |
<s>[INST]State of Alaska pet insurance regulatory filing objection: Under 7. EXPENSES, has actuarial support been provided to demonstrate compliance with AS 21.39.030(a) and 3 AAC 29.250(c)? Please provide the required support as per AS 21.39.040(d) and refer to regulations 3 AAC 29.300(11) and 3 AAC 31.230 for the necessary supporting documentation.[/INST] Expenses are based on the initial filing META-132852740 and have not changed.</s> |
<s>[INST]State of Alaska pet insurance regulatory filing objection: Objection 5 - Please provide an explanation of how the value for Ultimate Losses was determined using the values for D and C and the formula (D * C = Ultimate Losses) as stated in AS 21.39.040.[/INST] Thank you for bringing this to our attention. We have updated the Rate Increase Support Exhibit to provide a clear explanation of how ultimate losses are calculated.</s> |
<s>[INST]State of Alaska pet insurance regulatory filing objection: Please provide an explanation of how the value for Rate Level Adjustment was determined on pages 6 and 8, considering the values for F and G and the formula (F / G = Rate Level Adjustment) as per AS 21.39.040.[/INST] Thank you for bringing this to our attention. We have updated the Rate Increase Support Exhibit to address these errors.</s> |
<s>[INST]State of Alaska pet insurance regulatory filing objection: The objection letter is pending industry response. The objection was submitted on 04/18/2023 and a response is expected by 05/18/2023. The objection raises concerns about the adequacy of support provided for the director to determine if the filing meets the requirements of AS 21.39. It also questions the compliance of the proposed effective date with the waiting period requirement. The response is expected to address these concerns, identify any changes to the filing, and provide revised rate level impacts if necessary. Failure to respond within 30 days will result in disapproval of the filing. The objection also includes specific comments regarding incorrect changes in the marked copy, requesting that additions be underlined and deletions be shown with a strikethrough line.[/INST] The response letter has been submitted to the state. It was sent on 04/19/2023. The response acknowledges the objection and provides corrected redlined documents in response to the comments regarding incorrect changes in the marked copy. The response also references the objection's concerns about the marked copy not accurately reflecting the additions and deletions. The corrected redlined documents have been attached to the response.</s> |
<s>[INST]State of Alaska pet insurance regulatory filing objection: The objection letter is pending industry response. Adequate support has not been provided to determine if the filing meets the requirements of AS 21.39. The waiting period has not commenced, and the proposed effective date may not comply with the waiting period requirement. A new effective date may need to be requested in the response, allowing for a 30-day waiting period. Any changes to the filing must be identified, and revised rate level impacts must be provided if necessary. Failure to respond or request an extension within 30 days will result in disapproval of the filing. Late responses must be a complete resubmission addressing the questions and comments and referencing the tracking number. The response must be received before 3:00 pm Alaska time on the due date, or the next working day if received after 3:00 pm or on a weekend or state holiday. Objection 1: The Corresponding Filing Tracking Number field needs to be completed to reference the corresponding filing AXSS-G133634919. Objection 2: The marked copy and the final edition do not match. A revised marked copy showing changes must be attached.[/INST] In response to your objection letter dated 04/14/23, we have added the corresponding filing tracking number via Post Submission Update as requested. Please complete the Corresponding Filing Tracking Number field to reference the filing AXSS-G133634919. We have also attached the revised marked copies to address the discrepancies between the marked copy and the final edition.</s> |
<s>[INST]State of Alaska pet insurance regulatory filing objection: Please complete the Corresponding Filing Tracking Number field to reference the corresponding filing AXSS-G133611993. This is required as per 3 AAC 31.210(f)(2), 3 AAC 31.225(a)(12), and SERFF General Instructions, Comment 4.e. If the list of cross-referenced filings is too large for the Corresponding Tracking Number field, it can be provided in the response.[/INST] A post-submission update has been submitted for this revision.</s> |
<s>[INST]State of Alaska pet insurance regulatory filing objection: Objection 1 Comments: Response to[/INST] Response 1 Comments: Please refer to the attached response document. Related Objection 1 Comments: N/A</s> |
<s>[INST]State of Alaska pet insurance regulatory filing objection: Objection 1 - In the Fetch Pet Health Insurance Program Rate Manual, FRMNR 20230525.2, on pages 1-14, it is stated that the "Rating Plan Base Rate" section is intentionally left blank. However, the tables below mention calculating base rates using relativities. Please review and revise accordingly.[/INST] Please refer to the State Exception Page Alaska (page 2 of 10) for the requested information.</s> |
<s>[INST]State of Alaska pet insurance regulatory filing objection: The document mentions the introduction of new limits and states that factors were selected based on modeled values indicated by the GLM. Please provide additional information about the multivariate model used in developing the proposed rates and factors, including the model's structure, formula, assumptions, data used, variable selection process, adjustments made, validation methods, and how the resulting rates are appropriate and relevant in Alaska.[/INST] We refer the department to our filing with SERFF Tracking number XLAM-131970374. The GLM used in this filing was approved by the department on 11/5/2019 for effective dates of 1/7/2020 (New Business) and 3/7/2020 (Renewals). The current filing uses the approved factors as the basis for selecting factors for the new limits. No new model was run for this filing. The proposed factors for the new limits are based on the existing approved factors.</s> |
<s>[INST]State of Alaska pet insurance regulatory filing objection: The wording of the cancellation fee in the AK pages allows for a range of values. What criteria are used to determine the applicable cancellation fee? The manual should provide guidance to the underwriter for selecting the appropriate percentage or factor within the range, considering risk characteristics and compliance with Alaska Statute 21.39.030. It is suggested that a specific value for the cancellation fee be filed to simplify the rule.[/INST] We have revised our State Exception Page to remove any reference to a cancellation fee. We will not charge a fee when an insured initiates a policy cancellation. Please refer to the attached document, d SEPAK 20230721.pdf, and the accompanying redline from the current SEP provided in the Objection 1 response.</s> |
<s>[INST]State of Alaska pet insurance regulatory filing objection: This filing is disapproved under AS 21.42.123 and AS 21.42.130. It will only take effect if the division approves it based on additional information provided. Please respond to the raised issues within 30 days. If more time is needed, a written request for a 15-day extension can be made. The response must be received by 3:00pm Alaska time on the due date. If received after this time or on a weekend/state holiday, the response must be submitted by 3:00pm on the previous working day. Objection 1 - PET HEALTH INSURANCE POLICY TERMS AND CONDITIONS, GPTM 050, 0223 (Form): The Liberalization Clause may conflict with the entire policy. Consider adding a clause to the amendatory endorsement to endorse liberalized forms to the policy.[/INST] Thank you for your objection letter dated 05/30/2023. In response, the Company will remove the liberalization clause from the policy to comply with the state. Please refer to the attached redline and clean copy of the amendatory form that deletes that section.</s> |
<s>[INST]State of Arkansas pet insurance regulatory filing objection: Objection 1 - P&C Actuarial Justification (Supporting Document) Comments: All rate change requests must include supporting data as required by Arkansas Code Annotated § 23-67-209 (d). Please explain the consideration given to investment income related to premiums, reserves associated with premiums, and loss reserve funds.[/INST] Response 1 Comments: Please refer to our attached Support Exhibit - Investment Income. We have calculated the After-tax investment Income on Policyholder Supplied Funds using three components: Unearned Premium Reserves, Delayed Remission Of Premiums, and Loss & LAE Reserve. The data for each component is based on our historical records from Lemonade's 2019 and 2020 IEEs. Related Objection 1 Applies To: - P&C Actuarial Justification (Supporting Document) Comments: All rate change requests must include supporting data as required by Arkansas Code Annotated § 23-67-209 (d). Please explain the consideration given to investment income related to premiums, reserves associated with premiums, and loss reserve funds. Changed Items: No changes to Form Schedule items. No changes to Rate/Rule Schedule items. SERFF Tracking #: LEMO-133351241 State Tracking #: Company Tracking #: LIC-PET-AR-2208RR State: Arkansas Filing Company: Lemonade Insurance Company TOI/Sub-TOI: 09.0 Inland Marine/09.0004 Pet Insurance Plans Product Name: Pet Insurance Project Name/Number: Date: 06/13/2023 12:16 AM Supporting Document Schedule Item Changes: Satisfied - Item: P&C Actuarial Justification Comments: Attachment(s): AR Actuarial Memorandum.pdf, AR Factor Support.pdf, AR Pet Indication.pdf, Support Exhibit - Investment Income.pdf Previous Version Satisfied - Item: P&C Actuarial Justification Comments: Attachment(s): AR Actuarial Memorandum.pdf, AR Factor Support.pdf, AR Pet Indication.pdf</s> |
<s>[INST]State of Arkansas pet insurance regulatory filing objection: There is an error in the history of rate change section (15) of the actuarial memo. Please review and correct.[/INST] We apologize for the error. Please refer to the updated Act Memo, Arkansas - Actuarial Memorandum - 20221021.pdf, where we have corrected the history of rate adjustments to accurately reflect the effective dates and rate changes.</s> |
<s>[INST]State of Arkansas pet insurance regulatory filing objection: Please provide additional supporting documentation for the change to the area factor for Arkansas.[/INST] The rate levels in Arkansas are adjusted through the area factor to align with the overall indicated rate change. This can be observed on pages 8 and 9 of the submitted exhibit Arkansas - Exhibit - Experience - 20221005.pdf.</s> |
<s>[INST]State of Arkansas pet insurance regulatory filing objection: Objection 1 - NAIC loss cost data entry document (Supporting Document) is required with all rate change filings.[/INST] We have updated the NAIC loss cost data entry document as requested. Please note that this program does not utilize loss cost from advisory organizations. This is our first rate change filing.</s> |
<s>[INST]State of Arkansas pet insurance regulatory filing objection: The arbitration clause(s) in this filing need to be amended to comply with Ark. Code Ann. §23-79-203 and Arkansas Bulletin No. 19-89. Specifically, the clause(s) must state that it is non-binding and voluntary.[/INST] Please refer to Section X.E. The introductory section has been revised to explicitly state that the arbitration provision is voluntary and non-binding.</s> |
<s>[INST]State of Arkansas pet insurance regulatory filing objection: The territory rule needs to be amended to include reference to unlisted ZIP codes and the applicable factor.[/INST] Attached is the updated rate exception addressing the concern raised in the objection regarding the territory rule and unlisted ZIP codes.</s> |
<s>[INST]State of Arkansas pet insurance regulatory filing objection: Please explain how ZIP codes not listed are treated.[/INST] The Company has confirmed that a factor of 1.00 will be used for any zip codes not listed.</s> |
<s>[INST]State of Arkansas pet insurance regulatory filing objection: The reasons for cancellation in the Arkansas Amendatory Endorsement must comply with Arkansas Code Annotated §23-66-206 (15).[/INST] Attached is the updated Arkansas Amendatory Endorsement.</s> |
<s>[INST]State of Arkansas pet insurance regulatory filing objection: The objection letter is currently pending industry response. The objection letter was dated 01/30/2023 and submitted on the same date. A response is expected by a specified date.[/INST] The response letter has been submitted to the state on 02/17/2023. The response letter was also submitted on the same date.</s> |
<s>[INST]State of Arkansas pet insurance regulatory filing objection: Objection 1 - The NAIC loss cost data entry document is required for all rate change filings. Please complete the 5-year history section with policy count, premium, and loss experience for the time the program has been in effect in Arkansas. Additionally, provide the countrywide loss ratio. Objection 2 - Please provide a histogram showing the number of insureds receiving a greater than 20% increase.[/INST] Response 1 - Attached is the transmittal as requested. Response 2 - Please refer to the attached histogram and impact exhibits.</s> |
<s>[INST]State of Arkansas pet insurance regulatory filing objection: Objection 1 - NAIC loss cost data entry document (Supporting Document) Comments: The form needs to be amended to include premium, losses, and loss ratios in the 5-year history section. Even if there have been no rate changes in those years, the information in this section should reflect the most recent 5 years.[/INST] Response 1 Comments: Please refer to the updated NAIC loss cost data entry document.</s> |
<s>[INST]State of Arkansas pet insurance regulatory filing objection: The objection letter is pending industry response. The objection is regarding a redline of a revised form and requests an explanation for the new language added to the Cancellation and Nonrenewal section.[/INST] Thank you for your objection letter dated 05/08/2023. In response to your concern, please note that the new language "except if any condition above in item c is present" has been added to the Cancellation and Nonrenewal section due to the nature of the below cancellations. The specific reasons for cancellation are outlined in the amendatory endorsement, GPTM 100-AR 1221, which was approved in SERFF Filing # XLAM-133082668.</s> |
<s>[INST]State of Arkansas pet insurance regulatory filing objection: Objection 1 - The language in the Accident and Illness Policy Form (IAIC-PB10001-ILL) does not comply with Arkansas Code Annotated §23-66-206 (15). Additionally, it does not provide the required 20-day notice for reasons other than non-payment of premium. Please remove the "increasing your coverage 4(A)(2)" language.[/INST] Response 1 - The proposed language in the policy form allows policyholders to increase their coverage limits or add supplementary benefits, indicating a material change in their level of risk sharing with the insurance company. This aligns with Arkansas Code Annotated §23-66-206, which permits policy cancellations for six reasons, including the occurrence of a material change in the risk that substantially increases any insured hazard. This change is initiated by the policyholder, and if they do not make any changes to their coverage, the policy will remain in force.</s> |
<s>[INST]State of Arkansas pet insurance regulatory filing objection: Objection 1 - The Accident and Illness Policy Form, IAIC-PB10001-ILL, requires a policy to be cancelled and re-written if coverages are increased. Please explain the reason for this requirement.[/INST] We cancel and re-write the policy due to moral hazard concerns. When an insured increases coverage, there is a higher likelihood of increased claims frequency, with service/treatment dates occurring before or shortly after the coverage increase. By cancelling and re-writing the policy, we mitigate the risk of covering conditions where the service/treatment date preceded the policy effective date, reducing the potential for moral hazard.</s> |
<s>[INST]State of Arkansas pet insurance regulatory filing objection: Objection 2 - Accident and Illness Policy Form, IAIC-PB10001-ILL, (Form) - Please include the customer care center phone number in the submitting a claim information.[/INST] Please refer to the attached Amendatory Endorsement, which will be included and made a part of the policy form.</s> |
<s>[INST]State of Arkansas pet insurance regulatory filing objection: Objection 3 - EssentialWellness/BestWellness Endorsement, IAIC-PB10001-WLL, (Form) Please explain why the base policy must be cancelled if this endorsement is cancelled.[/INST] We cancel and re-write the policy for reasons of moral hazard. If an insured increases coverage, there is a strong likelihood that claims frequency will increase, with service/treatment dates occurring prior to or shortly after the date of coverage increase. By cancelling and re-writing the base policy, we reduce the possibility of moral hazard by not covering conditions where the service/treatment date preceded the policy effective date.</s> |
<s>[INST]State of Arkansas pet insurance regulatory filing objection: Please provide a list of states and SERFF Tracking numbers that have approved the "policy changes" language allowing termination of an existing policy that requires new enrollment.[/INST] Policy changes requiring termination of an existing policy would be initiated by the policyholder. Attached is a list of all states/filings that have approved the Policy Changes section of the policy form. States not listed do not require filing or approval of policy forms. Additionally, there is an approved competitor filing in AR under ICCC-133596572 citing similar language.</s> |
<s>[INST]State of Arkansas pet insurance regulatory filing objection: Objection 1 - The AR Amendatory Endorsement, PET-AE-20000-AR-, 0723 (Form), does not comply with ACA 23-66-206(15) as it deletes and replaces the "When We Cancel" provision without providing the required notice periods for cancellation. Objection 2 - Changes in the Accident and Illness Coverage, PET-P-20000-, 0723 (Form), result in new enrollment, termination of the existing policy, and the implementation of new waiting periods. Please explain these changes.[/INST] Response 1 - The form has been updated to reflect the proper notice time for cancellation. Response 2 - In situations where there is an expanded risk, an increase in policy limits, a change from Accident only to Accident/Illness coverage, or a mid-term change in deductible, a cancel/rewrite (new enrollment) may be required. The customer would be informed of this before making a decision to proceed.</s> |
<s>[INST]State of Arkansas pet insurance regulatory filing objection: The cancellation provision in the AR Amendatory Endorsement, PET-AE-20000-AR-, 0723 form does not comply with ACA 23-66-206 (15).[/INST] We have amended the form to ensure compliance with ACA 23-66-206 (15). The updated form, PET-AE-20000-AR-0723 -Final.pdf, is attached.</s> |
<s>[INST]State of Arkansas pet insurance regulatory filing objection: The "Pet Health Insurance Policy" information only references the accident policy form. The information in this form should also be included in the illness policy. Please explain.[/INST] We have created and attached an amendatory endorsement, TRSA-OPI-PC138-ILL-SAEN-AR, to be used with the Illness Policy.</s> |
<s>[INST]State of Arkansas pet insurance regulatory filing objection: The form name listed under the form schedule tab is "Arizona," but this is an Arkansas form.[/INST] The form name has been corrected to "Arkansas." Related Objection 2 Applies To: - Arkansas Amendatory Endorsement, TRSA-OPI-PC210-ACC-SAEN-AR, (03-23) (Form) Comments: The form name under the form schedule tab reads "Arizona." This is an Arkansas form. Changed Items: Form Schedule Item Changes ItemNo. FormName FormNumber EditionDate FormType FormAction ActionSpecificData ReadabilityScore Attachments Submitted 1 Arkansas Amendatory Endorsement TRSA-OPI-PC210-ACC-SAEN-AR (03-23) END New TRSA-OPI-PC210-ACC-SAEN-AR (03-23).pdf Date Submitted: 05/24/2023 By: Stephanie Marlow Previous Version 1 Arizona Amendatory Endorsement TRSA-OPI-PC210-ACC-SAEN-AR (03-23) END New TRSA-OPI-PC210-ACC-SAEN-AR (03-23).pdf Date Submitted: 05/19/2023 By: Stephanie Marlow No Rate/Rule Schedule items changed. No Supporting Documents changed.</s> |
<s>[INST]State of Arkansas pet insurance regulatory filing objection: Thorson Specialty Insurance Services does not appear to be licensed as an agency or MGA in Arkansas. Please explain.[/INST] A PSU (Policyholder Service Update) has been submitted. Thorson has changed its name to Norse Specialty Insurance Services.</s> |
<s>[INST]State of Arkansas pet insurance regulatory filing objection: The objection letter is pending industry response. The objection was submitted on 06/19/2023 and a response is expected by a certain date. The objection requests capping individual increases at 40%.[/INST] The response letter has been submitted to the state on 06/22/2023. The response acknowledges the inquiry regarding the Arkansas Pet Insurance filing and addresses the concerns raised. Individual increases have been capped at 40%. The updated filing packet and RF-1 Exhibit provide further details.</s> |
<s>[INST]State of Arkansas pet insurance regulatory filing objection: Please clarify the meaning of the chart labeled "Proposal $ Rate Impact" in supporting exhibit 5, page 2.[/INST] Thank you for your inquiry regarding our Arkansas Pet Insurance filing. The chart labeled "Proposal $ Rate Impact" represents the dislocation by dollar amount (in thousands) to our policies in force. For example, it shows that 35 policies in force will experience an increase between $100 and $200. If you have any further questions or concerns, please let us know. Thank you for your attention to this filing.</s> |
<s>[INST]State of Arkansas pet insurance regulatory filing objection: Please change the renewal effective date to 12/22/2023.[/INST] The renewal effective date will be amended to 12/22/2023 through a post-submission update. The rate information on the rate/rule schedule tab will also be updated accordingly. As a result of the new effective date, there have been slight changes in the proposed impact and the Accident & Illness and Accident Only Base Rates have been updated. Please refer to the updated filing and attached filing support for more details.</s> |
<s>[INST]State of Arkansas pet insurance regulatory filing objection: Please update the 5-year history section of the NAIC Loss Cost Data Entry document to include the most recent 5 years of data, even if there were no rate changes during those years.[/INST] We have revised the 5-year history section in the NAIC Loss Cost Data Entry document to include the most recent 5 years of data. For the years without rate changes, "No Rate Change" is indicated.</s> |
<s>[INST]State of Arkansas pet insurance regulatory filing objection: Please provide additional supporting documentation for the changes made to the pet age and new territory factors. Additionally, explain the reasoning behind the selected age factors.[/INST] Regarding the Underwriting Age and Tenure factors, further analysis was conducted for both dogs and cats. It was found that older age pets were being subsidized too significantly by younger pets, which could negatively impact new business. To address this, a minimum rate increase of +8.0% was selected for every tenure increase. Taking rates earlier in the pet's tenure allows for reduced rate increases later in the pet's life, improving retention and customer satisfaction. The minimum 8% increase also accounts for the "healthy pet discount," resulting in a manageable increase of approximately 3% from a customer experience perspective while maintaining positive premium drift. As for the territory factors, countrywide data from our Generalized Linear Model (GLM) was utilized. Geodemographic components of the GLM were used to guide the territory definition process and support the selected indications. Indications were calculated for each zip code based on scoring up the geodemographic components. Zip codes with similar indications were grouped together to form territories. The final territory indications are the averages across zip codes within each territory, weighted by earned exposures. Three geodemographic variables were used: the proportion of the population aged 25 and above with a bachelor's degree, the median rent for housing, and the population density within a zip code. These variables were selected for their predictive power and robustness.</s> |
<s>[INST]State of Arkansas pet insurance regulatory filing objection: Objection 4 - AR Pet Insurance Program, G-1-3, BR-1, GS-1, B-1, BL-1-12, UAT-1-13, T-1, D-1 (Rate) - Please provide the manual page for territory definitions.[/INST] Please refer to the attached document, Arkansas Territory Definitions, which provides the requested manual page for territory definitions.</s> |
<s>[INST]State of Arkansas pet insurance regulatory filing objection: For all rate change requests, Arkansas Code Annotated § 23-67-209 and Rule 23, Section 7.A.2 require supporting data. Please explain the consideration given to all investment income attributable to premiums, the reserves associated with those premiums, and loss reserve funds. Additionally, provide supporting documentation for the 10% trend assumption and the actual data referenced in the memo for each change derived from the claims experience of policies administered by MetLife. The proposed increases in this filing are significant and require sufficient data to support them.[/INST] Pet Insurance is an annually renewable term product that does not require long-term reserves like other Property & Casualty Products. The expected income generated from positive cash flow and reserves is 0.3% of premium. Please refer to the attached Trend Support 20230712 for documentation on the 10% trend assumption. The Factor Support Exhibit AR 20230712 provides all the data documenting each change mentioned in the memo.</s> |
<s>[INST]State of Arkansas pet insurance regulatory filing objection: Objection 2 - The rate manual must include a capping rule.[/INST] Please refer to the attached manual, which includes rate capping language from the actuarial memo. Additionally, we have provided a revised actuarial memo with an effective date of 8/4/23.</s> |
<s>[INST]State of Arkansas pet insurance regulatory filing objection: For all rate change requests, Arkansas Code Annotated § 23-67-209 and Rule 23, Section 7.A.2 require supporting data. Rate changes must be justified adequately.[/INST] Please refer to page 1 of the Rate Increase Support Exhibit AR for the requested supporting data.</s> |
<s>[INST]State of Arkansas pet insurance regulatory filing objection: Please explain the minimum premium note on the rating formula page.[/INST] The minimum premium is applicable to family plans with more than one pet. Its purpose is to ensure that adding another pet to the plan will result in an increase in the premium. Without this formula, there are a few cases where adding a pet could lead to a decrease in the overall premium.</s> |
<s>[INST]State of Arkansas pet insurance regulatory filing objection: Objection 3 - P&C Actuarial Justification (Supporting Document) Comments: Provide statistical documentation supporting the distribution channel factors.[/INST] Please refer to page 2 of the Rate Increase Support Exhibit AR for the requested statistical documentation supporting the distribution channel factors.</s> |
<s>[INST]State of Arkansas pet insurance regulatory filing objection: Objection 4 - P&C Actuarial Justification (Supporting Document) Comments: Please provide details regarding the rate cap of 4x.[/INST] Renewal rates will be capped at 40% for one year and then will transition to the full filed rate. This information has been updated in the actuarial memo.</s> |
<s>[INST]State of Arkansas pet insurance regulatory filing objection: The objection letter is pending industry response. There was an error in the SERFF link for the NAIC loss cost data entry document, and the attached form should be completed.[/INST] The completed documents have been attached, addressing the concerns raised in the objection.</s> |
<s>[INST]State of Arkansas pet insurance regulatory filing objection: The NAIC loss cost data entry document is required for all rate change filings, not just for loss cost filings.[/INST] Thank you for bringing this to our attention. The required documents, including the NAIC loss cost data entry document, have been added to the filing.</s> |
<s>[INST]State of Arizona pet insurance regulatory filing objection: The filing does not comply with Arizona statutes and/or administrative code. The objection is regarding the support for the proposed discounts, as a 0.7% difference in loss ratios does not appear to justify the discounts.[/INST] The company believes that the minimal 0.7% difference in loss ratios does support the proposed discounts. It should be noted that this loss ratio data includes discounts already active in the marketplace. If policyholders with discounts had significantly lower loss ratios compared to those without, it would suggest that the discounts should be larger.</s> |
<s>[INST]State of Arizona pet insurance regulatory filing objection: The filing does not comply with Arizona statutes and/or administrative code. Actuarial justification for the discounts provided in the product's affinity group program, strategic relationship discount, animal care discount, serving military, veteran, 1st responder and healthcare workers discount, and multi-policy discount has not been provided. The Department requests actuarial support for these discounts, including loss ratio data comparing policyholders receiving the discount to those who do not.[/INST] In response to Objection 1, national data is used to support the discounts, and loss ratio data shows that the discounts are actuarially sound. The loss ratio table below demonstrates that loss ratios are flat: Paid Loss Ratio No Discount: 85.8% Discount(s): 85.1% Total: 85.4% In response to Objection 2, please refer to the attached Exhibit - MetLife Fee Support for the requested supporting documentation regarding the fees shown in the rule page.</s> |
<s>[INST]State of California pet insurance regulatory filing objection: The deemer date for this filing is October 25, 2022. We request a waiver of the deemer provisions and ask that AXIS Insurance Company submits a SERFF note to waive the deemer provisions of California Insurance Code Section 1861.05.[/INST] Thank you for your Note to Filer. While we appreciate the explanation provided, we believe that the time frames established by Prop 103 are sufficient for reviewing and approving this filing. Therefore, we do not see a need to waive the rights granted to the company through the passage of Prop 103 at this time.</s> |
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