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<s>[INST]<<SYS>>Review this pet insurance filing.
Company: XL Specialty Insurance Company
Product: PetPlan Insurance Program 2021 Revision Filing
State: Alaska
Date: 09/01/2021
Description: Filing Description: Attached is a Filing Authorization Letter authorizing Martin & Company to submit this filing on behalf of XL Specialty Insurance Company (hereinafter referred to as The Company). Please direct all correspondence regarding this filing to Martin & Company. The Company is filing changes to its Pet Health Insurance Program. The rates and rating factors for this filing are updates to an existing filing. The overall impact of this filing is +6.3%. The company proposes an effective date of April 21, 2022 for new business and June 30, 2022 for renewal business.
<</SYS>>
Generate an objection to this filing.[/INST]
As we finish review of this filing, please update the Information on the Rate/Rule Schedule to reflect the latest indicated changes, rate impacts, premium change, and percentage changes for this filing. This can be done via post-submission update. 3 AAC 31.225(c)(2).</s><s>[INST]Generate a response to this objection.[/INST]A post submission update has been sent updating the overall % rate impact in the Filing Description section of the General Information tab. In addition, the Overall % Indicated Change, Overall % Rate Impact, Premium Change For This Program and the Maximum and Minimum % Change fields on the Rate/Rule Schedule tab.</s><s>[INST]Generate another objection to this filing.[/INST]Please identify what fees or expenses, in addition to Alaska's 2.7% premium tax, are included in the selected Taxes, Licenses, & Fees expense provision of 2.8%. AS 21.09.210(b)</s><s>[INST]Generate a response to this objection.[/INST]The Company has revised their Taxes, Licenses and fees provision from 2.8% to 2.7%. This selection revises their indication from +6.4% to +6.3%. The Company has provided the following revised indication exhibits in the attached file AK Objections 2021.12.16.pdf which are affected by the change in provision: Exhibit 1 Revised (2): Rate Change Summary Exhibit 2a Revised (2): Overall Rate Level Indication (Alaska Data Only) Exhibit 13a Revised (2): Permissible Loss Ratio - Alaska Furthermore, the proposed base rates have also changed. We have revised and are attaching the files AK SEP 20220421.pdf and accompanying redline AK SEP 20220421 Redline.pdf.</s><s>[INST]Responses that refer to PDF attachments or similar are not useful.[/INST]Acknowledged.</s><s>[INST]Generate another objection to this filing.[/INST]Please upload a copy of the circular being referenced for the miscellaneous tax of 0.34%, as the division does not have access to circulars. AS 21.39.040(d)</s><s>[INST]Generate a response to this objection.[/INST]While the Company does not subscribe to the captioned circular, the Company did receive information about the provision from a reliable source. However, because the Company is unable to provide the circular, the Company has examined company Taxes, Licenses and Fees experience specific to Alaska and selected a provision of 2.8%, rather than the filed provision of 3.04%. This experience is shown on the first page of the attached exhibit AK Objections 2021.11.15 Objection 1.pdf. This selection revises the Company's originally-filed indication from +6.7% to +6.4%. Accordingly, the same file includes the following revised indication exhibits which are affected by the change in provision: Exhibit 1 Revised: Rate Change Summary Exhibit 2a Revised: Overall Rate Level Indication (Alaska Data Only) Exhibit 13a Revised: Permissible Loss Ratio - Alaska Furthermore, the proposed base rates have also changed. The Company has revised and are attaching the files AK SEP 20220324.pdf and accompanying redline AK SEP 20220324 Redline.pdf.</s><s>[INST]Responses that refer to PDF attachments or similar are not useful.[/INST]Acknowledged.</s><s>[INST]Generate another objection to this filing.[/INST]Please provide Exhibit 10 for Cat and Dog individually rather than combined. AS 21.39.030 AS 21.39.040(d)</s><s>[INST]Generate a response to this objection.[/INST]Please see attached exhibit AK Objections 2021.10.21 Item 1.pdf.</s><s>[INST]Responses that refer to PDF attachments or similar are not useful.[/INST]Acknowledged.</s><s>[INST]Generate another objection to this filing.[/INST]In the response to Item 1.2.(a), please describe the miscellaneous tax of 0.34%. AS 21.39.030 AS 21.39.040(d)</s><s>[INST]Generate a response to this objection.[/INST]The Company references circular AS-CM-2020-002 as the source for this provision. </s><s>[INST]Generate another objection to this filing.[/INST]We observed that the maximum percentage change is 106.2%, and the minimum change is -77.1%. i) Please provide a histogram of policyholder impacts. ii) Please describe policy characteristics that are receiving impacts at or near the largest rate increase. iii) Please describe policy characteristics that are receiving impacts at or near the largest rate decrease. AS 21.39.040(d)</s><s>[INST]Generate a response to this objection.[/INST]i) Please see Page 1 of attached exhibit AK Objections 2021.10.21 Item 3.pdf. ii) Page 2 of attached exhibit AK Objections 2021.10.21 Item 3.pdf shows the policy characteristics of the policy receiving a +106.2% rate increase. The Breed Group is the characteristic driving the rate increase. iii) Page 2 of attached exhibit AK Objections 2021.10.21 Item 3.pdf shows the policy characteristics of the policy receiving a -77.1% rate decrease. The Breed Group is the characteristic driving the rate decrease.</s><s>[INST]Responses that refer to PDF attachments or similar are not useful.[/INST]Acknowledged.</s><s>[INST]Generate another objection to this filing.[/INST]Please provide additional information regarding the multivariate model used in developing the proposed rates and factors (where "model" includes any applicable component and/or submodels), including: (1) a description of the data used in the model, including whether the dataset was split into modeling, training, and holdout datasets. (2) a description and demonstration of the methods used to validate the output from the model (e.g. diagnostics, lift curves, stability test results, other statistical tests). Any applicable validation documentation should be accompanied by appropriate interpretive explanation, where appropriate. AS 21.39.040(d), AS 21.39.030(a), 3 AAC 29.220(a), 3 AAC 29.250(c)</s><s>[INST]Generate a response to this objection.[/INST](1) The training to holdout ratio was 2:1. Please refer to Exhibit 1 of the attached file AK Objections 2021.10.21 Item 4.pdf for a distribution of policyholders by state (including Canada). Exhibit 2 of the same file has a list of the variables used in the model, along with descriptions of their values and roles in the model. (2) Pearson correlation coefficients for explanatory variables were reviewed. Stability of coefficients for included variables was tested by checking the impact of removing others. No adjustments were made. Please refer to Exhibit 3 of the attached file AK Objections 2021.10.21 Item 4.pdf for a Pearson Correlation Matrix including variables used in the model. In addition, goodness of fit by variable was determined by reviewing observed vs. fitted pure premium charts using the holdout dataset, similar to the lift charts shown in Exhibit 4 of AK Objections 2021.10.21 Item 4.pdf.</s><s>[INST]Responses that refer to PDF attachments or similar are not useful.[/INST]Acknowledged.</s><s>[INST]Generate another objection to this filing.[/INST](1) Justify/provide rationale for the historical loss trend selection of 1.9% as shown on Exhibit 10. (2) Provide further detail for the expenses shown on Exhibit 13a, specifically: a.) What comprises "Taxes, Licenses and Fees", as the selection shown is 3.04%. Please note that state taxes are 2.7% (AS 21.09.210). b.) Support for the selected commission rate of 27.50%, and justification for it not being excessive. (3) Provide justification for the proposed Co-Pay Option factors shown on Appendix A pages 19 and 41, as they differ from indicated, especially at % reimbursed amounts of 70% and below. (4) Justify the inclusion of Canada within the Cat Country Territory Level as shown on Appendix A page 46, as the t-value is 0.1110. (5) Provide the filing number and date that the previous GLM was approved. (6) Clarify that the only item changing as part of the GLM analysis is a refresh of the relativities. I.e. variable selection, groupings, and the process of GLM1 and GLM2 are consistent with the previous iteration. AS 21.39.030, AS 21.39.040(d)</s><s>[INST]Generate a response to this objection.[/INST]Please see the attached response document and exhibits.</s><s>[INST]Responses that refer to PDF attachments or similar are not useful.[/INST]Acknowledged.</s> |
<s>[INST]<<SYS>>Review this pet insurance filing.
Company: Independence American Insurance Company
Product: Figo Rate Filing - 2023
State: Alaska
Date: 08/18/2022
Description: Filing Description: This filing is to present new and revised rates for the Independence American Insurance Company's line of pet health insurance administered and sold by Figo Pet Insurance LLC. The previous rate filing was approved on April 29, 2022 via SERFF ID# IADC-133064622. This filing updates base rates for trend and experience. State factors, breed factors, species-gender factors, weight factors and annual limit factors are updated for experience. This filing is not being done for any other purpose. We appreciate your review.
<</SYS>>
Generate an objection to this filing.[/INST]
Please justify a trend selection of 7% which is higher than all of the presented regressions within the trend exhibit. AS 21.39.030 AS 21.39.040(d)</s><s>[INST]Generate a response to this objection.[/INST]With this filing, we are proposing a non-wellness historical annual trend of 6.3%, corresponding with the 60-month regression results found in the support document, Exhibit - Trend Development - Alaska - 20220803.pdf. The experience used to develop rate indications is based on the same 60 months of data. With the current rate of inflation, we expect our prospective trend to be higher than we have observed in our historical data, and we are therefore using a prospective trend of 7.8%. We have submitted an additional support document, Exhibit - Veterinary Services CPU-U.pdf, showing the increase in Veterinary Services costs according to the Consumer Price Index for Urban areas, as calculated by the U.S. Bureau of Labor Statistics. The year-over-year comparisons have risen substantially in recent months, with single-month comparisons showing that the cost of veterinary services has increased up to 9.8% compared to the prior year. To account for this increase in base costs of veterinary services, we have selected a prospective trend of 7.8%, in line with year-over-year values we are seeing thus far in 2022. Using a historical trend of 6.3% to the end of the experience period of 3/1/2022 and a prospective trend of 7.8% from 3/1/2022 to the midpoint of the experience period, 1/1/2024, results in a combined, single annual trend of 7.0%.</s><s>[INST]Responses that refer to PDF attachments or similar are not useful.[/INST]Acknowledged.</s><s>[INST]Generate another objection to this filing.[/INST]Provide underlying expense and profit exhibits to support the expected loss ratio utilized in the rate level indication. If necessary, provide an explanation for any provisions that were selected based on judgment. AS 21.39.030 AS 21.39.040(d)</s><s>[INST]Generate a response to this objection.[/INST]Please see the attached file titled Figo Expense and Profit Support.pdf which contains the expense and profit exhibits to support the expected loss ratio of 58.1%.</s><s>[INST]Responses that refer to PDF attachments or similar are not useful.[/INST]Acknowledged.</s><s>[INST]Generate another objection to this filing.[/INST]Provide an explanation how the Proposed State Factor change is developed on Page 6 of 8 in the Rate Impact exhibits. If it is derived with quantitative support, please provide the exhibits. AS 21.39.030 AS 21.39.040(d)</s><s>[INST]Generate a response to this objection.[/INST]The proposed change to the state factor is the change necessary to meet the overall credibility adjusted statewide indicated change after all individual proposed factor changes are made. This is to allow breed factors, plan factors, age factors, and others to follow a largely nationwide schedule, while allowing each states rates to adjust in the manner their experience dictates. Page 7 of the experience exhibit shows that the overall proposed change calculated on page 6 matches the credibility adjusted rate level indicator.</s><s>[INST]Generate another objection to this filing.[/INST]Experience has improved in 2021 and 2022 on both a countrywide and Alaska basis. Please document any underlying drivers of the improved experience. AS 21.39.030 SERFF Tracking #: IAIC-133341142 State Tracking #: IAIC-133341142 Company Tracking #: FIGO RATE FILING - 2023 AK State: Alaska Filing Company: Independence American Insurance Company TOI/Sub-TOI: 09.0 Inland Marine/09.0004 Pet Insurance Plans Product Name: Figo Rate Filing - 2023 Project Name/Number: FIGO/ANNUAL FILING-2023 RATES PDF Pipeline for SERFF Tracking Number IAIC-133341142 Generated 01/03/2023 03:14 AM AS 21.39.040(d)</s><s>[INST]Generate a response to this objection.[/INST]Please note, the nationwide and Alaska experience included on page 1 of the experience represents the actual experience under the issued rates for both IAIC and the prior carrier. The rate adjustments in pages 2 through 7 is based on Adjusted Premium, where all prior experience is evaluated under the currently approved rate structure. With this response, 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 consistent with the rate work in this filing. Nationwide, the Adjusted Actual to Expected Loss ratio is much more consistent, ranging from 0.966 to 1.039. This supports that the nationwide driver of the improved experience is the rate adequacy associated with the policy since when viewed on the same rate level the experience is much more consistent. Alaska experience, particularly in older years, is very sparse and not very credible. In addition, calendar year 2022 only contains the first three months of experience, so statewide data, which is already limited, can be somewhat skewed. Ultimately, we aim to achieve a 1.00 Actual to Expected Loss Ratio both nationwide and in each state and aim to achieve this by analyzing the experience adjusted to the currently approved rates.</s><s>[INST]Responses that refer to PDF attachments or similar are not useful.[/INST]Acknowledged.</s><s>[INST]Generate another objection to this filing.[/INST]Experience has improved in 2021 and 2022 on both a countrywide and Alaska basis. Explain whether the more recent experience periods are better predictors of the prospective loss experience. AS 21.39.030 AS 21.39.040(d)</s><s>[INST]Generate a response to this objection.[/INST]As detailed in Objection 4 above, the experience improvement seen in 2021 and 2022 is related to the rate adequacy of the approved rates at IAIC and the prior carrier. Nationwide, when adjusting all experience to the currently approved rates, the experience each year is much more stable. As such, we believe the experience in years 2017 2020 is still a valid predictor of prospective loss experience and is reasonable to analyze alongside experience in years 2021 and 2022. Due to growth in the book of business, 2021 and 2022 represent 25% of the time frame (15 months of data in the 60 months of experience) yet accounts for 37% total exposures ((758,395 + 242,105)/2,695,809) and therefore do contribute a greater weight to the factor indications in pages 2 through 6 of the experience exhibit. Similarly for Alaska, 2021 and 2022 represent 50.1% of total exposures and will therefore account for a greater weight of the experience in determining the statewide indication. The experience in Alaska is not very credible; therefore, the overall requested rate change will be impacted by the overall credibility of 32.6% so that the full rate indication in the experience is not being requested, as is shown on page 7 of the experience exhibit. In addition, due to inflation and increasing veterinary costs, we believe prospective loss experience may increase in relation to premium compared to prior years. We have researched rising costs in the veterinary industry as seen in the attached file Exhibit Veterinary Services CPI-U.pdf, which shows substantially increasing claims cost trends in 2022.</s><s>[INST]Responses that refer to PDF attachments or similar are not useful.[/INST]Acknowledged.</s><s>[INST]Generate another objection to this filing.[/INST]Within the distribution of proposed rate increases, please document the general characteristics underlying the group of members receiving the greatest premium increases. AS 21.39.040(d)</s><s>[INST]Generate a response to this objection.[/INST]The pets receiving the largest premium increase are dogs with a fairly even split between male and female. The policies are mostly $10,000 or unlimited annual limit, a $500 deductible, and coinsurance of 100%. The policies are also largely on mixed breeds. Age is not a factor as there are no age factor changes proposed in this filing.</s><s>[INST]Generate another objection to this filing.[/INST]The Company is requesting its second rate increase greater than or equal to 10% in less than a year. Please summarize other actions being taken by the company, in addition to rate revision filings, to address overall profitability.</s><s>[INST]Generate a response to this objection.[/INST]Rate filing updates are a primary component in addressing overall profitability at this time in that they help ensure that premiums charged are adequate for the coverage provided and growing claims costs. The company utilizes regular reviews of the product, monitoring claims patterns, demographic changes, and emerging experience to ensure the product is meeting the needs of the customer base, is remaining competitive in the marketplace in pricing and coverage, and is priced appropriately. In the previous rate filing, with SERFF #IADC-133064622, we were limited by the department to a +10.0% rate increase though the experience resulted in a credibility weighted indication of +26.2%. As a result, we are now requesting an increase of +11.1% to achieve rate adequacy. Please note, our previous filing was initial submitted with an 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]Generate another objection to this filing.[/INST]What are the differences between pages 13 and 14? How do the rules differentiate? AS 21.39.040</s><s>[INST]Generate a response to this objection.[/INST]Page 13 and Page 14 of the rate manual provide the plan factors according to the adjudication method for the policy. The adjudication method is described in section II.E of the Underwriting Rules and Guidelines on page 2. Page 13 provides the factors for combinations of deductible and coinsurance under a Coinsurance First adjudication, in which 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]Generate another objection to this filing.[/INST]On page 9, there are revised Medical Base Rates proposed, which exhibits support these rating factor changes? Please provide support for the Proposed Medical Base Rates, 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.</s><s>[INST]Generate a response to this objection.[/INST]Base rates are updated for trend over the period of time since the previous effective date. The prior approved base rate in Alaska was developed for a 6/1/2022 effective date. Therefore, the proposed medical base rate for 1/1/2023 is developed by applying trend at a rate of 7% annually for 7 months: 1.07 7/12 = 1.04, or a 4% increase.</s> |
<s>[INST]<<SYS>>Review this pet insurance filing.
Company: Independence American Insurance Company
Product: PetsBest 01/2023 Rates
State: Alaska
Date: 09/30/2022
Description: Filing Description: This is a filing to present new and revised rates for the Independence American Insurance Company's line of pet health insurance as administered and sold by Pets Best, Inc. Base rates are updated for trend, and state factors. The estimated overall rate impact of this revision is an increase of 12.3%.
<</SYS>>
Generate an objection to this filing.[/INST]
Regarding the response to Objection #1; The marked copy shows changes to the prior authorized copy in filing IADC-132956232, which has an edition date of 08/19/2021, yet 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 to a form, rate, or rule filing must be attached to the Marked Copy section of the Supporting Documentation tab. The marked copy must show the new material underlined and the deleted material with a line stricken through it. 3 AAC 31.210(h), 3 AAC 31.299(1)</s><s>[INST]Generate a response to this objection.[/INST]Please see the updated marked copy.</s><s>[INST]Responses that refer to PDF attachments or similar are not useful.[/INST]Acknowledged.</s><s>[INST]Generate another objection to this filing.[/INST]3 AAC 31.230 Please provide expense information, both nationwide and specifically for this state, if available, as required by regulation 3 AAC 31.230(2)</s><s>[INST]Generate a response to this objection.[/INST]Please see the attached exhibit "Expense and Profit Support.pdf" </s><s>[INST]Responses that refer to PDF attachments or similar are not useful.[/INST]Acknowledged.</s><s>[INST]Generate another objection to this filing.[/INST]Please provide support for the Proposed Rates and Factors on pages 11 through 19, 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. SERFF Tracking #: IAIC-133417678 State Tracking #: IAIC-133417678 Company Tracking #: PETSBEST 01/2023 RATES - AK State: Alaska Filing Company: Independence American Insurance Company TOI/Sub-TOI: 09.0 Inland Marine/09.0004 Pet Insurance Plans Product Name: PetsBest 01/2023 Rates Project Name/Number: PETSBEST/ANNUAL FILING-2023 RATES PDF Pipeline for SERFF Tracking Number IAIC-133417678 Generated 01/03/2023 03:14 AM</s><s>[INST]Generate a response to this objection.[/INST]The support for the proposed factors on pages 11 through 19 can be found on page 2 of Alaska - Exhibit - Experience 20220923.pdf. Changes to the factors were not evaluated based on the deductible, coinsurance value or species, rather just the Limit Period (Policy Year or Per Incident) and Policy Type. Policy Type for medical plans equates to an annual limit. Please note that the changes to factors in the same tables found on pages 11 through 19 may vary slightly due to rounding.</s><s>[INST]Responses that refer to PDF attachments or similar are not useful.[/INST]Acknowledged.</s><s>[INST]Generate another objection to this filing.[/INST]The "marked copy" provided does not comply with Alaska state requirements. A clearly marked copy showing any changes to a form, rate, or rule filing must be attached to the Marked Copy section of the Supporting Documentation tab. THE MARKED COPY MUST SHOW THE NEW MATERIAL UNDERLINED AND THE DELETED MATERIAL WITH A LINE STRICKEN THROUGH IT. 3 AAC 31.210(h), 3 AAC 31.299(1) Note a thorough review of this filing is pending the above marked copy.</s><s>[INST]Generate a response to this objection.[/INST]We are confused by this objection as the marked copy format is the same we have used in previous filings without issue. The marked copy does have all new proposed rates underlined and all the rates that are being replaced with a line stricken through it per the state requirements. These can be seen on page 5 of the Alaska Rate Sheets Marked 20220921.pdf The first row has the new material underlined. The second row is the change. The third row has the old material with a line stricken through it. Please note that only the Medical Base Rate, and the Feline Illness, Cancer Only, Accident Only Base rates have changed on this page. The State Factor and Wellness Base rates have not changed, so are not underlined nor stricken out. The only other proposed changes in this filing are the plan factors that can be found on pages 11 through 19. All other factors remain unchanged.</s><s>[INST]Responses that refer to PDF attachments or similar are not useful.[/INST]Acknowledged.</s> |
<s>[INST]<<SYS>>Review this pet insurance filing.
Company: American Pet Insurance Company
Product: Trupanion Pet Health Insurance
State: Alaska
Date: 08/19/2022
Description: Filing Description: American Pet Insurance Company is filing to propose the following changes: Overall Rate Impact: 12% Proposed Effective Date: 11/01/2022 for new business and renewals The following changes are being made: Base Rate: Revising based on experience and in consideration of other proposed changes Geography Factors: Revising based on experience Age Factors: Revising dog factors based on experience Gender Factors: Revising based on experience
<</SYS>>
Generate an objection to this filing.[/INST]
Thanks for the updated exhibit to develop rating factors. As we finish our review, please further explain the normalization process for Paid Claims within the Dog Age curves. We expect that the normalization process is similar to the adjustment across columns (c) through (e) of the Gender exhibit but wanted to clarify. AS 21.39.040(d)</s><s>[INST]Generate a response to this objection.[/INST]The process is the same, in the age exhibit the normalized paid losses are calculated by adjusting paid losses by a composite deductible, breed, and geography factor for the age bucket.</s><s>[INST]Generate another objection to this filing.[/INST]Please document any distributional shifts that are occurring in the latest year that are leading to the negative premium trend from late 2020 to early 2022. AS 21.39.040(d)</s><s>[INST]Generate a response to this objection.[/INST]The negative premium trend is due to a shift of mix of business to lower cost breeds, younger age at enrollment, and higher deductibles.</s><s>[INST]Generate another objection to this filing.[/INST]Please document the underlying causes of the severity trend within pet insurance which is consistently near +15% based upon the regressions provided by the Company. AS 21.39.030 AS 21.39.040(d)</s><s>[INST]Generate a response to this objection.[/INST]Veterinary inflation trends and better access to higher quality of care are the main drivers for the severity trend consistently near +15% (for example more MRIs and less X-rays). On a country wide bases, the current veterinary CPI is at a 10.0% and we expect our forward looking PPPM loss trends to be comparable.</s><s>[INST]Generate another objection to this filing.[/INST]Please document the quantitative support or professional judgment utilized to select a 5.0% profit & contingency factor. AS 21.39.030 AS 21.39.040(d)</s><s>[INST]Generate a response to this objection.[/INST]Pet insurance is an extremely short tail line of business with little opportunity for investment income on held reserves. For this reason, we have decided to use the traditionally accepted underwriting profit provision of 5%.</s><s>[INST]Generate another objection to this filing.[/INST]For the Dog Age curves, please document how the Company selected factors. It appears that the Company more heavily relied upon the indicated relativity rather than the credibility adjusted factor while also correcting reversals. Please advise. SERFF Tracking #: APII-133373571 State Tracking #: APII-133373571 Company Tracking #: APIC-TRU-AK-20221101-RU State: Alaska Filing Company: American Pet Insurance Company TOI/Sub-TOI: 09.0 Inland Marine/09.0004 Pet Insurance Plans Product Name: Trupanion Pet Health Insurance Project Name/Number: / PDF Pipeline for SERFF Tracking Number APII-133373571 Generated 02/09/2023 11:13 PM If the company placed more weight on the indicated relativity rather than the credibility adjusted factor, please justify. AS 21.39.030 AS 21.39.040(d)</s><s>[INST]Generate a response to this objection.[/INST]Trupanion has updated the credibility adjusted factor formula to credibility adjust column titled Claims relativity key = .9 with column titled Current Factor. For older dogs, Trupanion more heavily relied on the indicated relativity, as the indicated relativity is in line with our 100% credible Book of Business factors.</s><s>[INST]Generate another objection to this filing.[/INST]Please review the submitted Rules and Rates along with the Marked Copy. We are not certain whether they are being filed correctly based upon the program that is currently approved. As one example, the filed rules now include the Landspath Food Program Factor which from our understanding is not a part of the current program nor has not been filed within this filing. Please advise or submit a Marked Copy along with Rules and Rates that align to this program and filing. AS 21.39.040(d)</s><s>[INST]Generate a response to this objection.[/INST]Respectfully removed the Landspath Food Program Factor from the Rules and Rates and Marked Copy. Submitting an updated Rules and Rates along with the Marked Copy to align with this program and filing.</s><s>[INST]Generate another objection to this filing.[/INST]Which table identifies the associated breed with the number? The table is not clear. AS 21.36.090(c) Will cats be unchanged in the rating? Is there a way to identify felines versus canines?</s><s>[INST]Generate a response to this objection.[/INST]Trupanion inadvertently did not include breed ID, age ID, and geo ID tables. URM Table 1 Pet Factor AK Key has been resubmitted to include associated breed with species and ID, associated Geo Region with Zip code, associated age at enroll with Age ID, and Gender with Gender ID. Cats will remain unchanged. Species can be identified in the Breed ID table in URM Table 1 Pet Factor AK Key.</s><s>[INST]Generate another objection to this filing.[/INST]This Table 1 is shown as a replacement. Please provide the marked copy per 3AAC 31.210(h). A clearly marked copy showing any changes to a form, rate, or rule filing must be attached to the Marked Copy section of the Supporting Documentation tab. The marked copy must show the new material underlined and the deleted material with a line stricken through it. 3 AAC 31.210(h), 3 AAC 31.299(1)</s><s>[INST]Generate a response to this objection.[/INST]Table 1 Pet Factor is replacing current Table 1 GEO Factors, Table 2 BREED Factors, Age at Enrollment Factors, Gender Factors. Trupanion is now including a redlined copy of the Table 1 Pet Factor, Table 1 GEO Factors, and Table 2 BREED factors.</s> |
<s>[INST]<<SYS>>Review this pet insurance filing.
Company: National Casualty Company
Product: Pet Insurance
State: Alaska
Date: 10/18/2022
Description: Filing Description: National Casualty Company (NCC) is submitting for your approval revisions to our existing rates for our VBW-I and VB-II Plans. We are also including an updated Appendix A, which lists companies participating within our voluntary benefits program. Employees of the listed companies are eligible for a 5% discount. WE ARE REQUESTING THE REVISED APPENDIX A TO BE CONSIDERED PROPRIETARY AND CONFIDENTIAL. Prior confidential status was granted under filing SCTT-132502187. We are requesting that this filing apply to all new business policies written effective on or after February 1, 2023, and all renewal policies effective on or after April 12, 2023, or within 90 days of the date of approval.
<</SYS>>
Generate an objection to this filing.[/INST]
Rate and form filings are public information after they become effective. See the applicable statute, AS 21.39.041(e), AS 21.39.220(g), AS 21.42.123(d), or AS 21.42.125(e). The filing will not be kept confidential. However, AS 21.06.060(f)(2) allows the director to designate certain types of information as confidential if the insurer makes a showing satisfactory to the director that the information is trade secret or proprietary business information. If you wish to pursue this option, you must provide a legal argument to the director clearly identifying what information you wish to be kept confidential and explaining why the information should be considered trade secret or proprietary business information. The request for confidentiality must be made directly to the director and not as a response or amendment in the filing.</s><s>[INST]Generate a response to this objection.[/INST]We understand the applicable statute and will not be requesting for confidentiality for this filing. Thank you for your continued review of this filing.</s> |
<s>[INST]<<SYS>>Review this pet insurance filing.
Company: National Casualty Company
Product: Pet Insurance
State: Alaska
Date: 10/18/2022
Description: Filing Description: National Casualty Company (NCC) is submitting for your approval a replacement to our existing coverage forms (VS-G-13-AK (1-21) and (VS-G-14-AK (1-21)) for our VBW-I and VB-II Plans with our updated VBW-I and VB-II coverage forms (VS-G-13 (01-23) VBW-I Coverage Form and (VS-14 (01-23) VB-II Coverage Form with an Amendatory Endorsement (VS-342-AK (01- 23) VBW-I & VB-II Amendatory Endorsement - ALASKA . We are updating our policy terms, review requirements, and definitions on our coverage form to offer additional clarity for our members and to align our defined terms with the definitions recently approved under the NAPHIA/NAIC Model Pet Act. We are requesting that this filing apply to all new business policies written effective on or after February 1, 2023, and all renewal policies effective on or after April 12, 2023, or within 90 days of the date of approval.
<</SYS>>
Generate an objection to this filing.[/INST]
Based on the authority given to the Director of Insurance, the division has issued the following guidance to insurers: The division suspends the file and use provisions under AS 21.39.220 and AS 21.42.125 for a period of 15 months. The division reserves the right to treat File and Use filings as Prior Approval if deemed necessary by the director. As per Regulatory Order R22-02, this filing will be treated as Prior Approval. Please revise the filing method to Prior Approval via post submission update. This order is effective May 1, 2022. It shall expire August 1, 2023. Thank you for your understanding.</s><s>[INST]Generate a response to this objection.[/INST]We will submit a Post Submission Update to correct this item.</s><s>[INST]Generate another objection to this filing.[/INST]Please update the filing description to reflect the correct form number. The filing description says "VS-432-AK" and the attached form number is "VS-342-AK".</s><s>[INST]Generate a response to this objection.[/INST]We will submit a Post Submission Update to correct this item.</s> |
<s>[INST]<<SYS>>Review this pet insurance filing.
Company: Independence American Insurance Company
Product: 2023 Individual Pet - Forms
State: Alaska
Date: 10/18/2022
Description: Filing Description: Form Number and Form Name IAIC-IND-2023-A-POL-AK - Accident Only Policy IAIC-IND-2023-AI-POL-AK - Accident and Illness Policy IAIC-IND-2023-DEC-XX - Declarations Page OPTIONAL BENEFIT RIDERS IAIC-IND-2023-R-DEN-XX - Routine Dental Treatment Benefit Rider IAIC-IND-2023-R-OV-XX - Office Visits and Examinations Benefit Rider IAIC-IND-2023-R-PC-XX - Preventive Care Benefit Rider IAIC-IND-2023-R-RXFOOD-XX - Prescription Food Benefit Rider IAIC-IND-2023-R-SUPP-XX - Dietary Supplements Benefit Rider IAIC-IND-2023-R-CI-XX - Cancer Treatment Indemnity Benefit Rider We are filing the above forms for review and approval. These forms are new and do not replace any previously filed forms. The corresponding rate filing has been submitted under SERFF ID# IAIC-133395340. To provide flexibility, all variable text is indicated by brackets. A Statement of Variability is also included in this filing. This filing does not contain any unusual or possible controversial items from industry standards. To the best of our knowledge, this filing is complete and intended to comply with the insurance laws of your state. The Company appreciates the Department’s time and consideration in the review of this filing. Thank you, Diane Marlowe Sr. Compliance Specialist Independence American Insurance Company 602-834-0776 telephone
<</SYS>>
Generate an objection to this filing.[/INST]
Promotional Items, Partner Promotional Items, Prizes, Contests, Sweepstakes, or Raffles, Special Promotions for Referrals, Special Promotions for Partner Referrals, and the alike are not compliant. Offering these types of benefits may be considered a form of rebating. (Alaska does not have a minimum value for rebating.) Further the Alaska DOI does not allow these types of benefits to be included in insurance policies as they are not considered to be relevant to the coverage being offered. These benefits may be offered, they just cannot be included in the policy. Alaska Statute 21.36.120(a)</s><s>[INST]Generate a response to this objection.[/INST]We maintain that for the reasons specified in our December 15, 2022 response to your Objection #4 on our corresponding rate filing (IAIC-133395340), it is our position that the promotional items, prizes and raffles, value-added services, and non-insurance services provisions would not, in and of themselves, be automatically deemed to be rebating.   That being said, based on your continued objection regarding these provisions in our rate filings, we have removed those provisions from our forms. We acknowledge your statement that you are not saying these benefits may be offered, they just cannot be included in the policy. In that same vein, is our understanding that the removal of such provisions at your request does not automatically preclude us from making such offerings available, provided, of course, that they are permissible in accordance with Alaska law and applied equally to similarly situated consumers. If our understanding on this topic is incorrect, please let us know. Please note, however, that we have not removed our Special Promotions for Referrals provision, as it is our position that providing a nominal one-time gift card or promotional item for a referral is not, in fact, a form of rebating and is not prohibited under Alaska law. In fact, AK § 21.27.370(c) specifically stipulates that a person who refers a customer or potential customer may be compensated for such referral, provided that the compensation is paid on a one-time basis in a nominal fixed amount and does not depend on whether the customer or potential customer ultimately purchases insurance. In our Special Promotions for Referrals language, we state that we may provide small rewards and incentives of nominal value, for customer referrals or if the policyholder recommends a person to us completes an application or obtains a quote. As such, our provision complies with Alaska law since the benefit for providing a referral lead is not contingent on the purchase of insurance, is nominal in value, and is not paid on a recurring basis.</s><s>[INST]Generate another objection to this filing.[/INST]Fraud and Misrepresentation of Material Fact: states "We may void this Policy if...." "If we void this Policy." "Voidance of this Policy will result in denial of all Claims" Please revise. Alaska Statute 21.42.110 states that misrepresentations, omissions, concealment of facts and incorrect statements may not prevent a recovery under the policy unless they are fraudulent, material to the acceptance of the risk or the hazard assumed, or the insurer in good faith would not have issued the policy or would have issued it differently if the true facts had been known. If the misrepresentations are not made in the application or do not meet the standards in AS 21.42.110, then AS 21.36.220 provides for a shortened notice period under which the insurer may cancel the policy. Under AS 21.36.220 the insurer may cancel the policy for discovery of fraud or material misrepresentation made by the insured or a representative of the insured in obtaining the policy rather than voiding it. The language voiding the policy for misrepresentations made at any time during the policy period violates these statutes.</s><s>[INST]Generate a response to this objection.[/INST]This provision in both policies has been revised to replace all reference to voiding coverage to cancelling the coverage.</s><s>[INST]Generate another objection to this filing.[/INST]For the Group Membership coverage or rate discounts, please provide a list of these associated groups who are eligible, this will give clear guidance to the underwriters who may apply these discounts with fair discrimination per AS 21.36.190(a-f).</s><s>[INST]Generate a response to this objection.[/INST]Please see our response objection #2 dated 11/02/2022 in corresponding rate filing IAIC-133395340.</s><s>[INST]Responses that refer to PDF attachments or similar are not useful.[/INST]Acknowledged.</s><s>[INST]Generate another objection to this filing.[/INST]The language states that "Assignment and Payment of Claims: Benefits will be paid upon receipt of a written Claim and receipt of any additional information requested by Us. Benefits will be paid directly to You". Regulation 3 AAC 26.070(a)(2) states that any person transacting a business of insurance who participates in the investigation, adjustment, negotiation or settlement of a first-party claim shall, within 30 working days after receipt of a properly executed statement of claim or proof of loss, pay those portions of the claim not in dispute.</s><s>[INST]Generate a response to this objection.[/INST]Thank you for your comments. After full review of 3 AAC 26.070, we modified our Right to Collect Information, Claims Under Investigation, and Assignment and Payment of Claims provisions to align our policy form more closely with the intent of the regulation.</s><s>[INST]Generate another objection to this filing.[/INST]These form mention Premium Discounts for certain policy holders. How is it determined which policy holders will receive a discount? Have the premium discounts been filed? Are there risk characteristics associated with this discount and are there rules or guidance on how underwriting can apply these consistently without discrimination? Regulation 3 AAC 29.400 - 3 AAC 29.469 provides guidelines on the use of schedule rating plans. In particular, section 415 has filing requirements. The manual must include the eligibility criteria, a description of each risk characteristic, the range of permissible debits or credits for each risk characteristic, the maximum debit or credit that may be assigned to the policy, and a statement describing compliance with the requirements of 3 AAC 29.420 and .430.</s><s>[INST]Generate a response to this objection.[/INST]The premium discounts and underwriting guidelines were submitted in corresponding filing tracking number IAIC- 133395340. For purposes of your form objection, we offer premium discounts to policyholders who meet certain underwriting criteria, thus making them eligible for one or more of the available discounts. The maximum discount available is 20%, and policyholders are only eligible for one discount in addition to the multi-pet discount. The discounts are applied based on information provided by the applicant that reveals such applicant is eligible for one or more of the available discounts. Please refer to the corresponding rate filing, and to our objection responses thereto, for additional information as to our discounts and the eligibility criteria used to ensure compliance.</s> |
<s>[INST]<<SYS>>Review this pet insurance filing.
Company: Independence American Insurance Company
Product: PPI 03 2023 Rates
State: Alaska
Date: 11/15/2022
Description: Filing Description: This is a rate only filing to present new and revised rates for the Independence American Insurance Company's pet health insurance administered and sold by PetPartners, Inc. Base rates are updated for trend. Various other factors are updated for experience as explained in the Actuarial Memorandum. This filing is not being done for any other purpose. Thank you for your consideration. Diane Marlowe Sr. Forms Development and Compliance Specialist dmarlowe@independenceamerican.com
<</SYS>>
Generate an objection to this filing.[/INST]
On page 2, Taxes, Licenses, & Fees are shown as 5.1%. Please identify what fees or expenses, in addition to Alaska's 2.7% premium tax, are included in the selected Taxes, Licenses, & Fees expense provision. AS 21.09.210(b)</s><s>[INST]Generate a response to this objection.[/INST]The 5.1% on page two represents the state premium tax of 2.7% as well state filing fees, certificate of authority fees, and state assessments. These amounts are taken from the statutory filings and are based on company wide data. Please note that the premiums developed in the filing are based on using a nationwide average of 2.75% for premium taxes and fees.</s><s>[INST]Generate another objection to this filing.[/INST]Please provide support for the revised Base Rates, 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.</s><s>[INST]Generate a response to this objection.[/INST]The Accident & Illness base rate is only being adjusted for annual claim cost trend at the 11% trend value displayed in the submitted file Exhibit - Trend Development Alaska - 20221104.pdf. The Accident Only base rate has been decreased to allow for the annual limit factors for both coverage categories to follow the same structure. Prior to the rate filing IADC-132707230, which was effective 4/21/2021, the annual limit factors did not vary based on the plan type. In that filing, a 40% reduction was applied to the annual limit factors for Accident Only plans. With this current filing, we are proposing one set of annual limit factors to apply to both plan types. Therefore, Accident Only policies will see a large increase in annual limit factors accompanied by a large decrease in their base rate. This decrease to the Accident Only plans base rate is calculated to be equivalent to the prior 40% decrease in annual limit factors as well as the annual trend increase both base rates experience. These two adjustments lead to our proposed Accident Only base rate change of (1-.40)*(1+0.11) = .666, or a decrease of 33.4%.</s><s>[INST]Responses that refer to PDF attachments or similar are not useful.[/INST]Acknowledged.</s> |
<s>[INST]<<SYS>>Review this pet insurance filing.
Company: National Casualty Company
Product: Pet Insurance Plans
State: Alaska
Date: 07/12/2022
Description: Filing Description: National Casualty Company (NCC) is submitting for your approval revisions to our existing rates and rules for our Major Medical Plan.
<</SYS>>
Generate an objection to this filing.[/INST]
Please fill out the Indicated Rate Change Percentage on the Rate/Rule Schedule to be consistent with the submitted filing support.</s><s>[INST]Generate a response to this objection.[/INST]The Rate/Rule Schedule will be updated to reflect the filing support.</s><s>[INST]Generate another objection to this filing.[/INST]The Company calculates an indicated rate need of -15.3%. The underlying experience for Alaska and Countrywide are stable across the three most recent years with projected ultimate loss ratios below the permissible loss ratio. Please specify why the proposed rates are reasonable but not excessive. Please submit any additional information to justify why no overall change is reasonable. AS 21.39.030</s><s>[INST]Generate a response to this objection.[/INST]For this filing, our focus is to refine our segmentation of the age and breed factors within the state of Alaska as opposed to changing the rate level. Therefore, we believe that taking neutral rate is appropriate for this rate review.</s><s>[INST]Generate another objection to this filing.[/INST]Please discuss the basis for the loss trend selections in Indication Exhibits 2 and 3. In particular please address the following observations: 1) The selected historical frequency selection of 8.3% exceeds the 4, 6, 8 and 12-point historical trends. While it does not exceed the 20-point historical trend, the indication only relies on the latest 3 years of loss experience. 2) The selected projected frequency selection of 4.6% exceeds the trends in the latest 2 years. 3) Both the selected historical and selected projected severity trends far exceed the historical trends observed in the data. Please provide support, as required by AS 21.39.040(d), to demonstrate compliance with AS 21.39.030(a) and 3 AAC 29.250(c).</s><s>[INST]Generate a response to this objection.[/INST]1.The historical frequency trend has been changed to the 12pt selection of 6.5%. 2.The projected frequency trend has been changed to the 8pt selection of 0.9%. 3.The historical and projected severity trends have been changed to the 12pt and 8pt selections, respectively. These changes have decreased the credibility-weighted indication to 15.3% but we will keep the selected rate change at 0% in order to keep our emphasis on improving our age and breed segmentation for this filing. We have included a new Indication Exhibits v2 with the updated trend selections and new indication.</s><s>[INST]Generate another objection to this filing.[/INST]Regarding the response to Objection #2 which states: "we are not requesting a rate change for the Plus level of coverage for this filing. We are only requesting a rate change for our Major Medical plan." So there is no confusion please remove the following 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)</s><s>[INST]Generate a response to this objection.[/INST]The sentence regarding Plus has been removed. Please see supporting document: AK Major Medical and Pet Wellness Plus Rider Filing Memo_updatedv2</s><s>[INST]Responses that refer to PDF attachments or similar are not useful.[/INST]Acknowledged.</s><s>[INST]Generate another objection to this filing.[/INST]Regarding the response to Objections #3 and 4, which filing has this information? How were the filing notes amended per the responses? Please file exhibits 1-4 for review. AS 21.39.040(d) Please provide support, 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.</s><s>[INST]Generate a response to this objection.[/INST]We discovered that the exhibits were not originally uploaded with the filing as we initially thought; they have been attached for your review and we apologize for the oversight. </s><s>[INST]Generate another objection to this filing.[/INST]Regarding the response to Objection #5, please specify which filing lists the groups that are subject to the discounts that can be found on page 18 of 19. SERFF Tracking #: NWPP-133329138 State Tracking #: NWPP-133329138 Company Tracking #: MMPWP10303NCCRR State: Alaska Filing Company: National Casualty Company TOI/Sub-TOI: 09.0 Inland Marine/09.0004 Pet Insurance Plans Product Name: Pet Insurance Plans Project Name/Number: /2022-PET-10303 MAJOR MEDICAL AND PLUS PDF Pipeline for SERFF Tracking Number NWPP-133329138 Generated 03/07/2023 11:50 PM This page states: "3)A 5% discount will be provided to different associations, affiliations and pet clubs that generate policies through marketing programs. 4) A 15% discount will be provided to Nationwide Associates." Please review AS 21.36.190</s><s>[INST]Generate a response to this objection.[/INST]Please see attached supporting exhibit (Appendix-B) that includes the list for associations, affiliations, and pet clubs.</s><s>[INST]Responses that refer to PDF attachments or similar are not useful.[/INST]Acknowledged.</s><s>[INST]Generate another objection to this filing.[/INST]Please fill out the Previous State Filing Number field on the Rate/Rule Schedule; see regulations 3 AAC 31.210(h) and 3 AAC 31.225(a)(10).</s><s>[INST]Generate a response to this objection.[/INST]The previous state filing number is: NWPP-132697124. We will make that update on the Rate/Rule Schedule.</s><s>[INST]Generate another objection to this filing.[/INST]This memo states "We are requesting a rate change on the Plus level of coverage which is outlined within the Pet Wellness Rider form (VS-281)" Within the Manual's Marked Copy on page N-VPI-MM-R-AK-3 the rate seems to have no changes. Where were these rate changes for the Pet Wellness Rider form (VS-281) filed? AS 21.39.040 Please provide support, 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.</s><s>[INST]Generate a response to this objection.[/INST]Our apologies, we are not requesting a rate change for the Plus level of coverage for this filing. We are only requesting a rate change for our Major Medical plan.</s><s>[INST]Generate another objection to this filing.[/INST]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, SERFF Tracking #: NWPP-133329138 State Tracking #: NWPP-133329138 Company Tracking #: MMPWP10303NCCRR State: Alaska Filing Company: National Casualty Company TOI/Sub-TOI: 09.0 Inland Marine/09.0004 Pet Insurance Plans Product Name: Pet Insurance Plans Project Name/Number: /2022-PET-10303 MAJOR MEDICAL AND PLUS PDF Pipeline for SERFF Tracking Number NWPP-133329138 Generated 03/07/2023 11:50 PM 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.</s><s>[INST]Generate a response to this objection.[/INST]The purpose of the Base Rate change is to offset the impact from the Age and Breed Factor adjustments. For this filing, we were targeting a neutral rate impact so a Base Rate change of -1.4% was applied to negate 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]Generate another objection to this filing.[/INST]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 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.</s><s>[INST]Generate a response to this objection.[/INST]The support for the Age and Breed factors can be shown in Supporting Exhibit 1 and 4. Additional details can be found in our Actuarial Memorandum and Indication Exhibits pertaining to being compliant with Alaskas rating laws.</s><s>[INST]Generate another objection to this filing.[/INST]On page N-VPI-MM-R-AK-4 it states "Discounts: 3) A 5% discount will be provided to different associations, affiliations and pet clubs that generate policies through marketing programs" Please review and revise per AS 21.36.190. An example of AS 21.36.190(a): An insurer, whether an authorized or unauthorized insurer, may not make available through a rating plan to a firm, corporation, or association of individuals, a preferred rate or premium based upon a fictitious group of the firm, corporation, or association of individuals.</s><s>[INST]Generate a response to this objection.[/INST]The 5% discount pertains to the cost savings associated with customers who enroll for an individual pet insurance policy through their affiliated groups. Affiliated groups promote or market to their members our pet insurance plans, allowing a 5% cost savings for National Casualty Company (NCC). The Company passes the cost savings on to policyholders through a 5% discount on their policy premium.</s> |
<s>[INST]<<SYS>>Review this pet insurance filing.
Company: Independence American Insurance Company
Product: 2023 Individual Pet - Rates
State: Alaska
Date: 10/18/2022
Description: Filing Description: This is a rate filing to accompany the corresponding form filing which has been submitted under SERFF ID# IAIC-133332534. This filing does not contain any unusual or possible controversial items from industry standards. To the best of our knowledge, this filing is complete and intended to comply with the insurance laws of your state. The Company appreciates the Department’s time and consideration in the review of this filing.
<</SYS>>
Generate an objection to this filing.[/INST]
To address your response, yes the company can offer these types of benefits, as long as they are not a part of the policy. That being said, the Underwriting and Rate Guideline for Alaska is still not compliant. The last page still references Special Promotions for Referrals. Please remove this section. Thank you. AS 21.36.120(a) and (b)</s><s>[INST]Generate a response to this objection.[/INST]Your initial objection was that [o]ffering [the] types of benefits (gifts, sweepstakes, prizes, contest[s], discounts and the like [that] may be considered a form of rebating. As such, we removed all related provisions from our underwriting rules and rating manual. Although we also revised our Special Promotions for Referrals provision, we did not remove it, as referrals were not specifically addressed in the objection. Additionally, it is our position that providing a nominal one-time gift card or promotional item for a referral is not, in fact, a form of rebating and is not prohibited under Alaska law. In fact, AK § 21.27.370(c) specifically stipulates that a person who refers a customer or potential customer may be compensated for such referral, provided that the compensation is paid on a one- time basis in a nominal fixed amount and does not depend on whether the customer or potential customer ultimately purchases insurance. In our Special Promotions for Referrals language, we state that we may provide small rewards and incentives of nominal value, for customer referrals or if the policyholder recommends a person to us completes an application or obtains a quote. It is our position, therefore, that our provision complies with Alaska law as the benefit for providing a referral lead is not contingent on the purchase of insurance, is nominal in value, and is not paid on a recurring basis. As such, we respectfully request that you reconsider your objection in this regard.</s><s>[INST]Generate another objection to this filing.[/INST]Regarding the response to Objection #4; Offering these types of benefits, (gifts, sweepstakes, prizes, contest, discounts and the like) may be considered a form of rebating. (Alaska does not have a minimum value for rebating as some states do.) Further, the Alaska DOI does not allow these types of benefits to be included in insurance policies as they are not considered to be relevant to the coverage or contact being offered. The Alaska DOI is not saying these benefits may be offered, they just cannot be included in the policy. Please revise. AS 21.36.090(c), AS 21.36.120(c).</s><s>[INST]Generate a response to this objection.[/INST]We maintain that for the reasons specified in our December 15, 2022 response to your Objection #4, it is our position that the promotional items, prizes and raffles, value-added services, and non-insurance services provisions would not, in and of themselves, be automatically deemed to be rebating. That being said, based on your continued objection regarding these provisions, we have removed those provisions and have revised the Special Promotions for Referrals provision to align with the information in Alaska Bulletin 2002-001 more closely. We acknowledge your statement that you are not saying these benefits may be offered, they just cannot be included in the policy. In that same vein, is our understanding that the removal of such provisions at your request does not automatically preclude us from making such offerings available, provided, of course, that they are permissible in accordance with Alaska law and applied equally to similarly situated consumers. If our understanding on this topic is incorrect, please let us know.</s><s>[INST]Generate another objection to this filing.[/INST]The Exhibit - Experience states: "The Base Rates are derived from the United States Fire Insurance Company filing" and "the Trupanion filing". When proposed rates and rules are based on those approved for another insurer, the filing should include supporting documentation to: (1) Identify differences in coverages, underwriting selection, target markets, special services offered, and company operating expenses versus the competitors; (2) Demonstrate how these differences are accounted for in the proposed rates; (3) Either: (i) identify the filings in which the competitor material was approved in Alaska, or (ii) attach a copy of the supporting documentation that was included by the competitor within the filings that were approved in other states. Do not attach the entire competitor filing. Please only attach the supporting exhibits of the competitor filing that are relevant and specific to the proposed rating; (4) Identify and explain how trends have been accounted for since the time the material has was approved for the competitors, and any adjustments that have been made to account for differences among filing jurisdictions (if applicable). AS 21.39.040(d), 3 AAC 29.220(a) Furthermore please the The Actuarial Memorandum states: " These rates are based on our review of similar programs available with other carriers as well as other IAIC programs" and the Exhibit - Experience states: "Independence American Insurance Company 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 PDF Pipeline for SERFF Tracking Number IAIC-133395340 Generated 03/07/2023 11:44 PM Figo filing" and "Independence American Insurance Company Pets Best and Pet Partners." Please attach the referenced support from these other IAIC program filings.</s><s>[INST]Generate a response to this objection.[/INST]Please see attached formal response letter along with additional exhibits.</s><s>[INST]Responses that refer to PDF attachments or similar are not useful.[/INST]Acknowledged.</s><s>[INST]Generate another objection to this filing.[/INST]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, this will give clear guidance to the underwriters who may apply these discounts with fair discrimination per AS 21.36.190(a-f).</s><s>[INST]Generate a response to this objection.[/INST]We currently do not have a list of specific entities that qualify for the above discounts as this is a new program that has not yet launched. We can confirm that once these entities are determined, they will be included in future rating manuals.</s><s>[INST]Generate another objection to this filing.[/INST]Page 34 discusses an Installment Fee. Fees associated with premium payment transactions, including late payment fees, insufficient funds fees, installment fees, and convenience fees, may not be charged until they have been filed and approved under the applicable statute, AS 21.39.041 or AS 21.39.220. See 3 AAC 26.885 for additional details.</s><s>[INST]Generate a response to this objection.[/INST]We can confirm that the fees associated with premium payment transactions, including late payment fees, insufficient funds fees, installment fees (found on page 31 of the rate manual), and convenience fees, may not be charged until they have been filed and approved.</s><s>[INST]Generate another objection to this filing.[/INST]Pages 35 and 36 Lists several Promotional Items and services, which are non-compliant. Please review and revise. Alaska Statute 21.36.120(a) states that an insurer may not pay, allow, give or offer as an inducement to insurance a rebate, discount, credit or reduction in premium or after insurance has been effected a rebate, discount, credit, special favor or advantage in the benefits, or any valuable consideration or inducement, not specified in the policy, except to the extent provide for in an applicable filing with the director. Also note that simply including an item considered to be a rebate or special favor in the policy language does not automatically ensure that it complies with Alaska law, including AS 21.36.090(c), AS 21.36.120(c).</s><s>[INST]Generate a response to this objection.[/INST]Please see attached formal objection response letter.</s><s>[INST]Responses that refer to PDF attachments or similar are not useful.[/INST]Acknowledged.</s><s>[INST]Generate another objection to this filing.[/INST]Please provide support for all the Proposed Rates and 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 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.</s><s>[INST]Generate a response to this objection.[/INST]The experience exhibit (Alaska Exhibit Experience 20221201) has been updated to include SERFF #s for approved filings used in the pricing of factors in the Alaska Spot filing. These approved factors were used as the factors in this filing and any deviations from these factors is noted on page 5 of the experience exhibit. For the deviation support, please see the Alaska deviation exhibit (Alaska Exhibit Deviations).</s> |
<s>[INST]<<SYS>>Review this pet insurance filing.
Company: WESTCHESTER FIRE INSURANCE COMPANY
Product: 23-PIM-2021957
State: Alaska
Date: 02/02/2023
Description: Filing Description: Westchester Fire Insurance Company (“the Company”) is filing a revision to its Pet Health program filed under the Inland Marine line of business and Pet Insurance Plan sub-line. The purpose of this filing is to increase the Monthly Base Loss Cost and Claim Fee Monthly Base Loss Cost by 3.0% to reflect the increase in average claim costs. The overall rate level indication of 8.6% was calculated on an effective quarter basis using the program’s experience. Regarding the determination of the overall rate level we analyzed the experience as follows: • Developed Alaska and countrywide losses to ultimate using historical development patterns. • Trended developed losses to prospective level. Actual countrywide experience for the program is utilized to support loss cost trend assumptions. • On-leveled premium to the current rates and factors by rerating individual pets. • Credibility-weight state-specific indication with countrywide indication. The impact of raising the Monthly Base Loss Cost and Claim Fee Monthly Base Loss Cost is 3.0%. The “Number of Policyholders Affected” figure entered in the SERFF Rate Information section represents the number of pets in-force in November 2022. The “Written Premium for this Program” figure represents the annualized premium associated for these in-force pets. Please see our attached proposed rating manual and redlined version. The Company respectfully requests that the proposed rates and rules be implemented for all policies effective 5/1/2023.
<</SYS>>
Generate an objection to this filing.[/INST]
The memo states: "Westchester Fire Insurance Company (the Company) is filing a revision to its Pet Health program" and has included a marked copy. Within the Rate/Rule Schedule tab please review and revise the Rate Action field from "new" to "replacement" and include the Previous State Filing Number. AS 21.39.040(d)</s><s>[INST]Generate a response to this objection.[/INST]Please see changes below.</s><s>[INST]Responses that refer to PDF attachments or similar are not useful.[/INST]Acknowledged.</s> |
<s>[INST]<<SYS>>Review this pet insurance filing.
Company: Independence American Insurance Company
Product: Group Pets 07 2023 Rates
State: Alaska
Date: 03/09/2023
Description: Filing Description: This is a rate only filing for the Independence American Insurance Company's group pet health insurance. Base rates are updated for trend. This filing is not being done for any other purpose. Thank you for your consideration. Diane Marlowe Sr. Forms Development and Compliance Specialist dmarlowe@independenceamerican.com
<</SYS>>
Generate an objection to this filing.[/INST]
Since there is no policies or experience for this filing, were the pricing trend assumptions based on its individual programs to increase the medical base rate by 10%? If the company used its individuals products, please provide the filings numbers. AS 21.39.040(d)</s><s>[INST]Generate a response to this objection.[/INST]Yes, since there are no policies or experience in AK for this filing the pricing trend assumption of 10% is based on the experience of the following individual program. Please see the attached file (Trend Exhibit 2022-12.pdf) for details of the basis of our trend assumption. Program - PPI SERFF Tracking # IAIC-133465505 Trend Rate - 11.0%</s><s>[INST]Responses that refer to PDF attachments or similar are not useful.[/INST]Acknowledged.</s> |
<s>[INST]<<SYS>>Review this pet insurance filing.
Company: United States Fire Insurance Company
Product: PET - V4.5
State: Alaska
Date: 12/16/2022
Description: Filing Description: The United States Fire Insurance Company (the Company) is filing to make the following changes to its pet medical program: Due to a change in product strategy, reintroduction of the Knee and Ligament coverage form and associate module; this form was originally approved under CRUM-131673047 and withdrawn in CRUM-132957653. There are no changes to the originally approved form aside from edition date.
<</SYS>>
Generate an objection to this filing.[/INST]
Based on the authority given to the Director of Insurance, the division has issued the following guidance to insurers: The division suspends the file and use provisions under AS 21.39.220 and AS 21.42.125 for a period of 15 months. The division reserves the right to treat File and Use filings as Prior Approval if deemed necessary by the director. As per Regulatory Order R22-02, this filing will be treated as Prior Approval. Please revise the filing method to Prior Approval via post submission update. This order is effective May 1, 2022. It shall expire August 1, 2023. Thank you for your understanding.</s><s>[INST]Generate a response to this objection.[/INST]A post submission update has been submitted to amend the filing method to prior approval.</s><s>[INST]Generate another objection to this filing.[/INST]The marked copy does not appear to have any underlined or stricken through material. Please review and resubmit a clearly marked copy. A clearly marked copy showing any changes to a form, rate, or rule filing must be attached to the Marked Copy section of the Supporting Documentation tab. The marked copy must show the new material underlined and the deleted material with a line stricken through it. 3 AAC 31.210(h), 3 AAC 31.299(1)</s><s>[INST]Generate a response to this objection.[/INST]We apologize for the oversight. The marked copy has been removed from the Supporting Documentation tab.</s><s>[INST]Generate another objection to this filing.[/INST]Within this filing a marked copy is attached yet the Form Schedule indicates this form to be new. Please clarify if this is a new or replaced form. If the form is replaced please revise the Action Specific Data and include the Previous Filing # within it's respective field on the Form Schedule; see regulations 3 AAC 31.210(h), 3 AAC 31.299(1), and 3 AAC 31.225(a)(10). SERFF Tracking #: USAI-133463383 State Tracking #: USAI-133463383 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: / PDF Pipeline for SERFF Tracking Number USAI-133463383 Generated 07/05/2023 07:52 AM</s><s>[INST]Generate a response to this objection.[/INST]The form is being introduced is new, as it was withdrawn under CRUM-132957653. The redline copy was simply to show no changes since it was last filed. To avoid further confusion this document has been removed from the filing.</s> |
<s>[INST]<<SYS>>Review this pet insurance filing.
Company: United States Fire Insurance Company
Product: PET - V4.5
State: Alaska
Date: 12/16/2022
Description: Filing Description: The United States Fire Insurance Company (the Company) is filing to make the following changes to its pet medical program: Overall rate revision of +2.3%. Segmentation of the base rates by production channel. Revision of coinsurance factors. Revision of breed factors and breeds. Creation of territory factors and reclassification of zip codes. Due to a change in product strategy, reintroduction of the Knee and Ligament coverage module. Removal of transition rule. Introduction of a veterinary expense payment service.
<</SYS>>
Generate an objection to this filing.[/INST]
Please review and revise the Previous State Filing Number field on the Rate/Rule Schedule as the referenced filing number is a Form filing and its' corresponding Rate/Rule filing does not appear to be similar to Replaced R/R/ Manual or it's Marked Copy; see regulations 3 AAC 31.210(h) and 3 AAC 31.225(a)(10). Please provide an updated marked copy. A clearly marked copy showing any changes to a form, rate, or rule filing must be attached to the Marked Copy section of the Supporting Documentation tab. The marked copy must show the new material underlined and the deleted material with a line stricken through it. 3 AAC 31.210(h), 3 AAC 31.299(1)</s><s>[INST]Generate a response to this objection.[/INST]The previous state filing number has been amended on the Rate/Rule Schedule tab. The updated marked copy of the Rate/Rule Manual was added to the previous objection and uploaded to the Supporting Documentation tab.</s><s>[INST]Generate another objection to this filing.[/INST]Please complete the Corresponding Filing Tracking Number field, via post-submission update, to reference the corresponding filings. See 3 AAC 31.210(d)(4), 3 AAC 31.210(g), and 3 AAC 31.225(a)(12) and SERFF General Instructions, Comment 4.e which outlines the cross-referencing requirement. If the list of cross-referenced filings is too large for the Corresponding Tracking Number field, the list can be provided in your response.</s><s>[INST]Generate a response to this objection.[/INST]The corresponding tracking number (USAI-1334633830) has been added via a post-submission update.</s><s>[INST]Generate another objection to this filing.[/INST]The marked copy does not appear to have any underlined or stricken through material. Please review and resubmit a clearly marked copy. A clearly marked copy showing any changes to a form, rate, or rule filing must be attached to the Marked Copy section of the Supporting Documentation tab. The marked copy must show the new material underlined and the deleted material with a line stricken through it. 3 AAC 31.210(h), 3 AAC 31.299(1)</s><s>[INST]Generate a response to this objection.[/INST]We apologize for the oversight. A corrected version of the markup document has been uploaded. As well, a revised version of the finalized rate/rule manual has been added due to a missing item. Thank you!</s> |
<s>[INST]<<SYS>>Review this pet insurance filing.
Company: AXIS Insurance Company
Product: Pet Health
State: Alaska
Date: 05/25/2023
Description: Filing Description: SERFF Tracking #: AXSS-G133613284 State Tracking #: AXSS-G133613284 Company Tracking #: FETCH-2023-03-0022-AK State: Alaska Filing Company: AXIS Insurance Company TOI/Sub-TOI: 09.0 Inland Marine/09.0004 Pet Insurance Plans Product Name: Pet Health Project Name/Number: 2023 FETCH Wellness Form Revision/FETCH-2023-03-0022 PDF Pipeline for SERFF Tracking Number AXSS-G133613284 Generated 07/24/2023 04:49 A
<</SYS>>
Generate an objection to this filing.[/INST]
3 AAC 31.225(b)(2) requires that the filing method be provided in the Filing Method field within the State Specific Tab in SERFF. The company indicates this form filing to be under the Prior Approval method. Please be advised that the "File and Use" Compliance Certificate is only required for form filings filed under the F&U filing method. This filing is being treated under the Prior Approval method as indicated and in accordance with Regulatory Order R22-02.</s><s>[INST]Generate a response to this objection.[/INST]Acknowledged.</s><s>[INST]Generate another objection to this filing.[/INST]The amended definition of "Covered Expenses" does not comply with Alaska Statute. Upon review of the previously filed and Closed-Approved filing; MRTN-132783780 and the Objection Letter dated 05/05/2021, Objection #5 addresses this issue as follows. Please review and revise. "Regarding the definition of "Covered Expenses": The rating for this endorsement does not appear to consider or account for the existence of any "other insurance" or "benefit program" available to a particular insured. Accordingly, the purported restriction results in excessive premiums for those insureds that have purchased overlapping coverage, in violation of Alaska Statute 21.39.030(a)(1). An insured is entitled to receive the full benefits for which he or she has paid up to the point of full indemnification. Please revise. AS 21.42.130"</s><s>[INST]Generate a response to this objection.[/INST]In response to this objection, the company has amended the definition of Covered Expenses in each of the forms to remove the language addressing costs covered by any other insurance or benefit program. Please see the updated versions of these endorsements submitted with this response.</s><s>[INST]Responses that refer to PDF attachments or similar are not useful.[/INST]Acknowledged.</s> |
<s>[INST]<<SYS>>Review this pet insurance filing.
Company: Metropolitan General Insurance Company
Product: 2023 Pet Rate Change Filing
State: Alaska
Date: 03/29/2023
Description: Filing Description: This is a rate filing to present revised rate materials, for approval, for Metropolitan General Insurance Company’s currently approved pet insurance product. The filing was approved on 9/8/2021, under SERFF Tracking Number: (META-132852740). These revised rates are based on a review of historical data for policies by Metropolitan General Insurance Company. The rate manual and actuarial memorandum included in this filing will apply to new policies issued as well as renewals of in force policies. If you have any questions or concerns regarding the enclosed materials, please let us know. Thank you for your attention to this matter. Thank you, Vincent Li, AVP & Pricing Actuary
<</SYS>>
Generate an objection to this filing.[/INST]
The final copy was not filed under the Rate/Rule Schedule, please review and revise.</s><s>[INST]Generate a response to this objection.[/INST]The final copy (revised version) of the Pet Manual is submitted with this response.</s><s>[INST]Generate another objection to this filing.[/INST]With Alaska's Premium Tax at 2.7% per AS 21.09.210(b)(1), is the selected 2.1% for Taxes, Licenses and Fees appropriate?</s><s>[INST]Generate a response to this objection.[/INST]Response: Thank you for pointing this out. Please see the updated actuarial memo which updates from 2.1% to 2.7%. </s><s>[INST]Responses that refer to PDF attachments or similar are not useful.[/INST]Acknowledged.</s><s>[INST]Generate another objection to this filing.[/INST]Under 7. EXPENSES has actuarial support been provided? Please provide support, 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.</s><s>[INST]Generate a response to this objection.[/INST]Response: Expenses are based on me too of initial filing META-132852740 and have not changed.</s><s>[INST]Generate another objection to this filing.[/INST]Please show how the value for Ultimate Losses was developed given the values for D and C and the formula (D * C = Ultimate Losses) AS 21.39.040</s><s>[INST]Generate a response to this objection.[/INST]Response: Thank you for pointing out this error. Please see the updated Rate Increase Support Exhibit which clarifies how ultimate losses are calculated. </s><s>[INST]Responses that refer to PDF attachments or similar are not useful.[/INST]Acknowledged.</s><s>[INST]Generate another objection to this filing.[/INST]Please show how the value for Rate Level Adjustment was developed within pages 6 and 8 given the values for F and G and the formula (F / G = Rate Level Adjustment) AS 21.39.040</s><s>[INST]Generate a response to this objection.[/INST]Response: Thank you for pointing this out. Please see the updated Rate Increase Support Exhibit which corrects these errors.</s><s>[INST]Responses that refer to PDF attachments or similar are not useful.[/INST]Acknowledged.</s><s>[INST]Generate another objection to this filing.[/INST]Please review and show how the value for Trended Incurred Claims, Adjusted Incurred Loss Ratio, Permissible Loss Ratio, Rate Level Adjustment, Rebased Adjustment, Credibility Weighted Adjustment (E-J) was developed. AS 21.39.040</s><s>[INST]Generate a response to this objection.[/INST]Response: The company respectfully requests additional information for this objection as formulas for requested fields are shown at the bottom of each factor development page. </s> |
<s>[INST]<<SYS>>Review this pet insurance filing.
Company: AXIS Insurance Company
Product: Pet Health
State: Alaska
Date: 03/31/2023
Description: Filing Description: AXIS Insurance Company ("the Company") is filing updated rates factors used in its Pet Health Insurance Program ("the Program"), which is designed to provide reimbursement of veterinary medical expenses to owners of dogs and cats for illness or injury to their covered pet. The purpose of this filing is to present updated rate factors and to demonstrate that the resulting rates are reasonable, not excessive, inadequate, or unfairly discriminatory. We believe that the information contained in this filing are sufficient to demonstrate the above. This filing is not intended to be used for other purposes.
<</SYS>>
Generate an objection to this filing.[/INST]
Objection #2 response: The changes to the marked copy are still incorrect. The marked copy must show what is being added (underlined) and deleted (strikethrough). To be clear, here are a few examples, but not limited to: 1. On the INDEX TO RATING RULES, the last two categories, Premium Determination and Introductory Policy Coverage and Pricing, show page 14 being deleted, and that these two sections are now found on page 13, since 13 is underlined. On the final edition, it shows that these are actually still on page 14. 2. On page 4 of the marked copy under Payment Plans it shows the following being added, since it is all underlined: "The payment plan fee is in addition to the insurance premium described in the Premium Determination section. If a policyholder elects to pay in full the annual premium, there is no additional payment plan fee" Yet in the final edition this cannot be found under Payment Plans, nor can it be found anywhere within the final edition. 3. The final copy has the following listed under Payment Plans and Fees "Paper Check Processing Fee: A $3 per transaction fee applies if the customer elects to SERFF Tracking #: AXSS-G133611993 State Tracking #: AXSS-G133611993 Company Tracking #: FETCH-2023-03-0021-AK State: Alaska Filing Company: AXIS Insurance Company TOI/Sub-TOI: 09.0 Inland Marine/09.0004 Pet Insurance Plans Product Name: Pet Health Project Name/Number: 2023 FETCH Rate Revision/FETCH-2023-03-0021 PDF Pipeline for SERFF Tracking Number AXSS-G133611993 Generated 08/21/2023 04:42 AM receive a paper check in lieu of direct deposit for claim payment. Optional Touchless Claims Service Fee: $8 per claim if the claimant elects to provide such notice. Fetch Insurance Service will obtain medical records from the claimants provider and process the claim." This language cannot be found in the marked copy as an addition. A clearly marked copy showing any changes to a form, rate, or rule filing must be attached to the Marked Copy section of the Supporting Documentation tab. The marked copy must show the new material underlined and the deleted material with a line stricken through it. 3 AAC 31.210(h), 3 AAC 31.299(1)</s><s>[INST]Generate a response to this objection.[/INST]Attached are the corrected redlined documents.</s><s>[INST]Generate another objection to this filing.[/INST]Please complete the Corresponding Filing Tracking Number field, via post-submission update, to reference the corresponding filing AXSS-G133634919. See 3 AAC 31.210(f)(2) and 3 AAC 31.225(a)(12)</s><s>[INST]Generate a response to this objection.[/INST]Per your request, we have added the corresponding filing tracking number via Post Submission Update.</s><s>[INST]Generate another objection to this filing.[/INST]There are several areas where the marked copy and the final edition do not match. Please revise. A clearly marked copy showing any changes to a form, rate, or rule filing must be attached to the Marked Copy section of the Supporting Documentation tab. The marked copy must show the new material underlined and the deleted material with a line stricken through it. 3 AAC 31.210(h), 3 AAC 31.299(1)</s><s>[INST]Generate a response to this objection.[/INST]Attached are the revised marked copies.</s> |
<s>[INST]<<SYS>>Review this pet insurance filing.
Company: AXIS Insurance Company
Product: Pet Health
State: Alaska
Date: 04/13/2023
Description: Filing Description: Under SERFF Tr Num: AXSS-G132998235, an approved filing, the Company submitted a filing which included the form Pet Health Insurance Policy Terms and Conditions, GPTM 050 0120 A. The Company is filing a revised Pet Health Insurance Policy Terms and Conditions, GPTM 050 0223 A. The company is primarily adding clarifying language to the form(s). We have attached in the supporting documentation a complete red-lined copy and a final clean copy of form GPTM 050 0223 A and all other forms submitted with this filing, if applicable.
<</SYS>>
Generate an objection to this filing.[/INST]
Please complete the Corresponding Filing Tracking Number field, via post-submission update, to reference the corresponding filing AXSS-G133611993. See 3 AAC 31.210(f)(2) and 3 AAC 31.225(a)(12) and SERFF General Instructions, Comment 4.e. which outlines the cross-referencing requirement. If the list of cross-referenced filings is too large for the Corresponding Tracking Number field, the list can be provided in your response.</s><s>[INST]Generate a response to this objection.[/INST]A post submission update has been submitted for this revision.</s><s>[INST]Generate another objection to this filing.[/INST]Based on the authority given to the Director of Insurance, the division has issued the following guidance to insurers: The division suspends the file and use provisions under AS 21.39.220 and AS 21.42.125 for a period of 15 months. The division reserves the right to treat File and Use filings as Prior Approval if deemed necessary by the director. As per Regulatory Order R22-02, this filing will be treated as Prior Approval. Please revise the filing method to Prior Approval via post submission update. This order is effective May 1, 2022. It shall expire August 1, 2023. Thank you for your understanding.</s><s>[INST]Generate a response to this objection.[/INST]A post submission update has been submitted for this revision.</s> |
<s>[INST]<<SYS>>Review this pet insurance filing.
Company: XL Specialty Insurance Company
Product: Fetch Pet Health Insurance Program 2023 Revision Filing
State: Alaska
Date: 05/03/2023
Description: Filing Description: Attached for your review is a Filing Authorization Letter from XL Specialty Insurance Company (hereinafter referred to as The Company) authorizing Martin & Company to submit this filing on their behalf. Please direct all correspondence regarding this filing to Martin & Company. In accordance with the regulatory provisions of your state, the Company is filing changes to its Pet Health Insurance Program. The rates and rating factors for this filing are updates to an existing filing. The overall impact of this filing is +11.1%. The company proposes an effective date of August 17, 2023 for new business and October 31, 2023 for renewal business. Should you have any questions or require additional information, please do not hesitate to contact us.
<</SYS>>
Generate an objection to this filing.[/INST]
Response to Objection 2 was inadequate. In filing XLAM-131970374, Exhibit 4 of the Rate Manual support for the Annual Policy Maximum Limits table was based on existing premiums, losses and trends. Since the new factors did not appear to be interpolated values, a model was conjectured. How were the new values derived? The GLM from the previous filing was not applicable to this table. Please provide support for the Proposed Annual Policy Maximum Limits of $6-9,000, 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.</s><s>[INST]Generate a response to this objection.[/INST]Please see the attached response document.</s><s>[INST]Responses that refer to PDF attachments or similar are not useful.[/INST]Acknowledged.</s><s>[INST]Generate another objection to this filing.[/INST]On page 3 under the Policy Option Pricing it states: "Rating Plan Base Rate. This section is intentionally left blank." Then the tables below say "The Base Rates for a specific state may be calculated by applying the following relativities to the Base Rates shown above:" Kindly review the page and revise accordingly.</s><s>[INST]Generate a response to this objection.[/INST]Please refer to the State Exception Page Alaska (page 2 of 10) for this information.</s><s>[INST]Generate another objection to this filing.[/INST]The document states, "We are also introducing new limits of $6,000, $7,000, $7,500, $8,000, $9,000 and $12,500. Because we have no experience at these limits, we have selected the factors based on the modelled values indicated by the GLM. See our manual for these factors." What was the model? Please provide additional information regarding the multivariate model used in developing the proposed rates and factors (where "model" includes any applicable component and/or sub-models), including: (1) the model's structure and formula and any specific assumptions that were used in the model, including any user identified parameters. (2) a description of the data used in the model, including (i) identification and description of external datasets incorporated into the model, and (ii) how the dataset was split into modeling, training, and holdout datasets. SERFF Tracking #: XLAM-133661775 State Tracking #: XLAM-133661775 Company Tracking #: 23SX-XP-CM01-MU-AK-R State: Alaska Filing Company: XL Specialty Insurance Company TOI/Sub-TOI: 09.0 Inland Marine/09.0004 Pet Insurance Plans Product Name: Fetch Pet Health Insurance Program 2023 Revision Filing Project Name/Number: Fetch Pet Health Insurance Program 2023 Revision Filing/23SX-XP-CM01-MU-AK-R PDF Pipeline for SERFF Tracking Number XLAM-133661775 Generated 08/21/2023 04:45 AM (3) a definition of all variables included in the model; a description of the process used to determine what variables to include and reject; a description of the process used to partition/group/bin the variables in an optimal manner; and identification and definitions of variables that: (i) are included in the model but are not used in rating (e.g. controls), (ii) fixed in the model as offsets, and/or (iii) were considered but rejected. (4) identification and explanation for any adjustments made to the model input or output; (5) a description and demonstration of the methods used to validate the output from the model (e.g. diagnostics, lift curves, stability test results, other statistical tests). The validation should be provided for the model in aggregate as well as for each component or sub-model. Documentation should also demonstrate the predictiveness of each variable and the accuracy of (or uncertainty associated with) the estimated values. The validation should also compare the selected solution to the current rating plan to demonstrate its relative accuracy. Any applicable validation documentation should be accompanied by appropriate interpretive explanation, where appropriate. and (6) an explanation describing how the various data, adjustments, validation, etc. ensure that the resulting rates are appropriate and relevant prospectively in Alaska. AS 21.39.040(d), AS 21.39.030(a), 3 AAC 29.220(a), 3 AAC 29.250(c)</s><s>[INST]Generate a response to this objection.[/INST]We refer the department to our filing, SERFF Tracking number XLAM-131970374. This filing used a GLM which was the basis for all rating factors, including the limit factors. The filing, and thus the GLM, was approved by the department on 11/5/2019 for effective dates of 1/7/2020 (New Business) and 3/7/2020 (Renewals). Our current filing uses these approved factors as the basis for selection of the factors for the new limits. We selected factors for these limits so as to pass the Miccolis consistency tests while gradually transitioning from the selected factors at $5,000 to the indicated factors at $10,000. The factors for $12,500 produce a similar consistent transition between the indicated factors at $10,000 and $15,000. 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]Generate another objection to this filing.[/INST]Under the expense table, the footnote (1) states: "All provisions are countrywide, except for Taxes, Licenses and Fees, which is Alaska-specific." AS 21.09.210(b)(1) indicates that taxes are 2.7%. Please provide additional information for the 3.04% shown in Exhibit 7, thanks.</s><s>[INST]Generate a response to this objection.[/INST]The added 0.34% is a load for miscellaneous tax as found in ISO circular AS-CM-2022-002.</s> |
<s>[INST]<<SYS>>Review this pet insurance filing.
Company: XL Specialty Insurance Company
Product: Fetch Pet Health Insurance Program 2023 Revision Filing
State: Alaska
Date: 05/03/2023
Description: Filing Description: Attached for your review is a Filing Authorization Letter from XL Specialty Insurance Company (hereinafter referred to as The Company) authorizing Martin & Company to submit this filing on their behalf. Please direct all correspondence regarding this filing to Martin & Company. Under SERFF Tr Num: XLAM-133097103 and State Tr Num: XLAM-133097103, an approved filing, the Company submitted a filing which included the form Pet Health Insurance Policy Terms and Conditions, GPTM 050 1221. In accordance with the regulatory provisions of your state, the Company is submitting for your review and approval a revised Pet Health Insurance Policy Terms and Conditions, GPTM 050 0223. The company is primarily adding clarifying language to the form. The company is also expanding coverage by removing the annual exam clause as it related to claims handling. By removing this language, a condition found after a missed annual exam will not be excluded from coverage. The Company has attached in the supporting documentation a red-lined copy, and a final clean copy of form GPTM 050 for your review with changes outlined above. Be advised the forms are system-generated and may be formatted differently due to system constraints. The content, however, will remain the same. Therefore, the forms will not be re-filed unless otherwise requested by your Department in response to this filing. Also, please be advised that variable fields are shown in brackets. The bracketed fields will be populated with the respective information, which is administrative in nature. The variable information may be subject to change and does not have an impact on the overall coverage provided by the policy. Should you have any questions or require additional information, please do not hesitate to contact us.
<</SYS>>
Generate an objection to this filing.[/INST]
The Liberalization Clause, item 8 in Other Terms and Conditions, may conflict with the entire policy. Please review and consider adding a clause to the amendatory endorsement to endorse liberalized forms to the policy. Policy must contain entire contract per AS 21.42.150. The policy, when issued, shall contain the entire contract between the parties, and neither the insurer nor its agent or representative, nor a person insured by the policy, may make an agreement as to the insurance that is not expressed in the policy. This section does not prohibit the modification of a policy, after issuance, by written rider or endorsement issued by the insurer.</s><s>[INST]Generate a response to this objection.[/INST]The Company will remove the liberalization clause from the policy to comply with the state. Please see the attached redline and clean copy of the amendatory form to delete that section.</s><s>[INST]Responses that refer to PDF attachments or similar are not useful.[/INST]Acknowledged.</s> |
<s>[INST]<<SYS>>Review this pet insurance filing.
Company: Lemonade Insurance Company
Product: Pet Insurance
State: Arkansas
Date: 09/16/2022
Description: Filing Description: A revision to Lemonade’s pet insurance program is hereby submitted for the State’s review. The proposed rate level change for the Accident & Illness coverage is 25% and the proposed change for Preventative coverage is 10%. Please see the attached rate indication for support of this rate level adjustment. We are also proposing to update our rating factors, which helps improve our ability to properly classify risks within our rating plan. Please see the attached filing memorandum for further details.
<</SYS>>
Generate an objection to this filing.[/INST]
All request for rate changes submitted to the Department must include supporting data as required by Arkansas Code Annotated § 23-67-209 (d). Explain the consideration given to all investment income attributable to premiums and to the reserves associated with those premiums and to loss reserve funds.</s><s>[INST]Generate a response to this objection.[/INST]Please see our attached Support Exhibit - Investment Income. We determined the After-tax investment Income on Policyholder Supplied Funds based on three components: Unearned Premium Reserves, Delayed Remission Of Premiums and Loss & LAE Reserve. The data for each component is from our historical record (Lemonades 2019 and 2020 IEEs).</s><s>[INST]Responses that refer to PDF attachments or similar are not useful.[/INST]Acknowledged.</s><s>[INST]Generate another objection to this filing.[/INST]Please provide the number of insureds receiving increases greater than 25%.</s><s>[INST]Generate a response to this objection.[/INST]There are 98 insureds receiving an increase greater than 25% with this filing proposal.</s> |
<s>[INST]<<SYS>>Review this pet insurance filing.
Company: Independence American Insurance Company
Product: PPI 03 2023 Rates
State: Arkansas
Date: 10/14/2022
Description: Filing Description: This is a rate only filing to present new and revised rates for the Independence American Insurance Company's pet health insurance administered and sold by PetPartners, Inc. Base rates are updated for trend. Various other factors are updated for experience as explained in the Actuarial Memorandum. This filing is not being done for any other purpose. Thank you for your consideration. Diane Marlowe Sr. Forms Development and Compliance Specialist dmarlowe@independenceamerican.com
<</SYS>>
Generate an objection to this filing.[/INST]
There appears to be an error in the history of rate change section (15) of the actuarial memo. Please review and correct.</s><s>[INST]Generate a response to this objection.[/INST]We apologize. Please see the updated Act Memo, Arkansas - Actuarial Memorandum - 20221021.pdf in which we have corrected the history of rate adjustments to reflect the correct effective dates and rate changes.</s><s>[INST]Responses that refer to PDF attachments or similar are not useful.[/INST]Acknowledged.</s><s>[INST]Generate another objection to this filing.[/INST]Please provide additional supporting documentation for the change to the area factor for Arkansas.</s><s>[INST]Generate a response to this objection.[/INST]Rate levels are adjusted specific to Arkansas through the area factor to meet the overall indicated rate change from the rate level indications. This can be seen in pages 8 and 9 of the submitted exhibit Arkansas - Exhibit - Experience - 20221005.pdf.</s><s>[INST]Responses that refer to PDF attachments or similar are not useful.[/INST]Acknowledged.</s><s>[INST]Generate another objection to this filing.[/INST]For the 18 insureds receiving greater than 25% increases, identify the changes in the filing impacting these policies. Have these insureds filed claims?</s><s>[INST]Generate a response to this objection.[/INST]These 18 insureds have $100 deductible and/or 90% coinsurance plans. Both the deductible and coinsurance factors have proposed adjustments based on experience, with these characteristics receiving rate increases. Some, but not all, of these 18 insureds have filed claims.</s> |
<s>[INST]<<SYS>>Review this pet insurance filing.
Company: Liberty Insurance Underwriters Inc.
Product: Pet Insurance
State: Arkansas
Date: 10/19/2022
Description: Filing Description: This filing serves to revise pet health insurance program, Pet Insurance Plan (“the Program”), on behalf of Liberty Insurance Underwriters, Inc. (“LIUI”). With this filing, rates, rules are being revised. Enclosed is authorization for Perr&Knight to submit this filing on behalf of the Company. All correspondence related to this filing should be directed to Perr&Knight. If there are any requests for additional information related to items prepared by the Company, we will forward the request immediately to the Company contact. The Company’s response will be submitted to your attention as soon as we receive it.
<</SYS>>
Generate an objection to this filing.[/INST]
This form is required with all rate change filings.</s><s>[INST]Generate a response to this objection.[/INST]As per the request, we updated this form as best we could. Note, this program does not use loss cost from advisory organizations. This is the first rate change filing.</s> |
<s>[INST]<<SYS>>Review this pet insurance filing.
Company: Liberty Insurance Underwriters Inc.
Product: Pet Insurance
State: Arkansas
Date: 10/19/2022
Description: Filing Description: This filing serves to revise pet health insurance program, Pet Insurance Plan (“the Program”), on behalf of Liberty Insurance Underwriters, Inc. (“LIUI”). With this filing, forms are being revised. Enclosed is authorization for Perr&Knight to submit this filing on behalf of the Company. All correspondence related to this filing should be directed to Perr&Knight. If there are any requests for additional information related to items prepared by the Company, we will forward the request immediately to the Company contact. The Company’s response will be submitted to your attention as soon as we receive it.
<</SYS>>
Generate an objection to this filing.[/INST]
The arbitration clause(s) found in this filing should be amended to comply with Ark. Code Ann. §23- 79-203 and Arkansas Bulletin No. 19-89. The clause(s) must specifically state it is non-binding and voluntary.</s><s>[INST]Generate a response to this objection.[/INST]Please refer to Section X.E. The introductory section is revised to state that the provision is voluntary and non-binding.</s><s>[INST]Generate another objection to this filing.[/INST]Please provide a copy of the notice to insureds regarding reduction in coverage and other changes to the policy.</s><s>[INST]Generate a response to this objection.[/INST]The Notice of <<Cancellation/Non-renewal>> is provided.</s> |
<s>[INST]<<SYS>>Review this pet insurance filing.
Company: Cimarron Insurance Company, Inc.
Product: Pet Insurance Program
State: Arkansas
Date: 11/28/2022
Description: Filing Description: Cimarron Insurance Company, Inc. (“Company”) respectfully submits this initial filing for rates, rules and rating factors for a new Pet Health Insurance Program. This program does not replace any rates or rules currently on file in this jurisdiction. This comprehensive plan provides coverage against accidents and illnesses for cats and dogs. The program is underwritten by Cimarron Insurance Company, Inc. and administered by Kanguro Insurance, LLC. Because this is the Company’s initial filing for this type of insurance, there is no existing or historical data from which to develop the rates and/or rating factors. Therefore, the proposed rating plan is based on competitor analysis, relying heavily on the program approved in Florida for American Southern Home Insurance Company, and underwriting expertise. The Company believes the proposed rating plan results in premiums that are adequate, not excessive and not unfairly discriminatory. The Company will closely monitor the performance of this program, and will submit a revised rating plan if the experience demonstrates a need to do so. The forms to be used in coordination with the enclosed rates have been filed under separate cover letter as Company filing #: PIP-22-001-F (AR).
<</SYS>>
Generate an objection to this filing.[/INST]
The territory rule must be amended to include reference to unlisted ZIP codes and the applicable factor.</s><s>[INST]Generate a response to this objection.[/INST]Attached is the updated rate exception.</s><s>[INST]Generate another objection to this filing.[/INST]Please explain how ZIP codes not listed are treated.</s><s>[INST]Generate a response to this objection.[/INST]The Company has confirmed that a factor of 1.00 will be used for any zip codes not listed.</s> |
<s>[INST]<<SYS>>Review this pet insurance filing.
Company: Cimarron Insurance Company, Inc.
Product: Pet Insurance Program
State: Arkansas
Date: 11/28/2022
Description: Filing Description: Cimarron Insurance Company, Inc. (“Company”) respectfully submits this initial filing for forms for a new Pet Health Insurance Program. This program does not replace any forms currently on file in this jurisdiction. This comprehensive plan provides coverage against accidents and illnesses for cats and dogs. The program is underwritten by Cimarron Insurance Company, Inc. and administered by Kanguro Insurance, LLC. The rates and rules to be used in coordination with the enclosed forms have been filed under separate cover letter as Company filing #: PIP-22-001-R (AR).
<</SYS>>
Generate an objection to this filing.[/INST]
The reasons for cancellation must comply with Arkansas Code Annotated §23-66-206 (15).</s><s>[INST]Generate a response to this objection.[/INST]Attached is the updated Arkansas Amendatory.</s> |
<s>[INST]<<SYS>>Review this pet insurance filing.
Company: Accredited Surety and Casualty Company, Inc.
Product: ManyPets Pet Insurance Program
State: Arkansas
Date: 01/06/2023
Description: Filing Description: Accredited Surety and Casualty Company, Inc. (the "Company") is submitting a rate update filing for its currently approved ManyPets Pet Insurance Program. A letter permitting Westmont Associates, Inc. to file on the Company's behalf is enclosed. The Company is proposing to increase the monthly base rate to reflect the increasing cost of veterinary medical care caused by changes in fees, utilization and scope of services. The Company is also including rating factor revisions as well. If you have any questions or concerns regarding the enclosed materials, please let us know. Thank you for your attention to this matter.
<</SYS>>
Generate an objection to this filing.[/INST]
This form is required with 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 even though a rate change has not been filed. Provide the countrywide loss ratio.</s><s>[INST]Generate a response to this objection.[/INST]Attached is the transmittal per your request.</s><s>[INST]Generate another objection to this filing.[/INST]Provide a histogram showing the number of insureds receiving greater than a 20% increase.</s><s>[INST]Generate a response to this objection.[/INST]Please refer to the attached histogram and impact exhibits.</s> |
<s>[INST]<<SYS>>Review this pet insurance filing.
Company: XL Specialty Insurance Company
Product: Fetch Pet Health Insurance Program 2023 Revision Filing
State: Arkansas
Date: 05/03/2023
Description: Filing Description: Attached for your review is a Filing Authorization Letter from XL Specialty Insurance Company (hereinafter referred to as The Company) authorizing Martin & Company to submit this filing on their behalf. Please direct all correspondence regarding this filing to Martin & Company. In accordance with the regulatory provisions of your state, the Company is filing changes to its Pet Health Insurance Program. The rates and rating factors for this filing are updates to an existing filing. The overall impact of this filing is +4.6%. The company proposes an effective date of June 15 for new business and August 29, 2023 for renewal business. Should you have any questions or require additional information, please do not hesitate to contact us.
<</SYS>>
Generate an objection to this filing.[/INST]
Please amend the form to include premium, losses and loss ratios in the 5-year history section. The information in this section should reflect the most recent 5-years even if there have been no rate changes in those years.</s><s>[INST]Generate a response to this objection.[/INST]Please see the updated NAIC loss cost data entry document.</s><s>[INST]Responses that refer to PDF attachments or similar are not useful.[/INST]Acknowledged.</s><s>[INST]Generate another objection to this filing.[/INST]Please provide the number of insureds receiving greater than 25% increases. Indicate the changes in the filing contributing to the impact of the 25% or greater increases.</s><s>[INST]Generate a response to this objection.[/INST]In determining the impact of the proposed rate change, the Company has rerated every policy in-force at September 30, 2022 under the proposed rate schedule, using its current policy characteristics. Because the Company's new Healthy Pet Credit (HPC) uses multiple years of data, the Company went back to inception for every policy and considered its loss history in determining what the HPC would be under the new rules. In doing that exercise, the Company found 57 policies that would receive a rate increase over +25%. This was solely driven by a change from an existing No Claims Credit (NCC) of 30% (factor of 0.70) to a Healthy Pet Credit of 0% (factor of 1.00). For the majority of the policies experiencing rate increases over +25%, this is because a policyholder is not eligible for the proposed HPC until it enters its fourth year of coverage, while a policy which is claims-free for its first 2 years would enter its third year of coverage with a NCC of 30%. Note, however, that the Company has proposed rules which grandfather the existing NCC, eliminating the possibility that a policy which renews would move from a factor of 0.70 to 1.00. In terms of a premium increase, the largest premium increase a renewing customer would experience solely due to the change from NCC to HPC rules, is +21.4% (going from a NCC of 30% to a HPC of 15%). On top of that, a renewing customer would experience a base rate change of +2.7% or -5.9% for Cat or Dog, respectively. The customer would also experience a premium increase due to the aging of the pet.</s> |
<s>[INST]<<SYS>>Review this pet insurance filing.
Company: XL Specialty Insurance Company
Product: Fetch Pet Health Insurance Program 2023 Revision Filing
State: Arkansas
Date: 05/03/2023
Description: Filing Description: Attached for your review is a Filing Authorization Letter from XL Specialty Insurance Company (hereinafter referred to as The Company) authorizing Martin & Company to submit this filing on their behalf. Please direct all correspondence regarding this filing to Martin & Company. Under SERFF Tr Num: XLAM-133082668, an approved filing, the Company submitted a filing which included the form Pet Health Insurance Policy Terms and Conditions, GPTM 050 1221. In accordance with the regulatory provisions of your state, the Company is submitting for your review and approval a revised Pet Health Insurance Policy Terms and Conditions, GPTM 050 0223. The company is primarily adding clarifying language to the form. The company is also expanding coverage by removing the annual exam clause as it related to claims handling. By removing this language, a condition found after a missed annual exam will not be excluded from coverage. The Company has attached in the supporting documentation a red-lined copy, and a final clean copy of form GPTM 050 for your review with changes outlined above. Be advised the forms are system-generated and may be formatted differently due to system constraints. The content, however, will remain the same. Therefore, the forms will not be re-filed unless otherwise requested by your Department in response to this filing. Also, please be advised that variable fields are shown in brackets. The bracketed fields will be populated with the respective information, which is administrative in nature. The variable information may be subject to change and does not have an impact on the overall coverage provided by the policy. Should you have any questions or require additional information, please do not hesitate to contact us.
<</SYS>>
Generate an objection to this filing.[/INST]
Please explain the intent of the new language "except if any condition above in item c is present" that has been added to the Cancellation and Nonrenewal 6 f.</s><s>[INST]Generate a response to this objection.[/INST]Due to the nature of the below cancellations, the cancellation may be prejudice to any claim occurring prior to the effective date of cancellation if the policy is cancelled for the following reasons per the amendatory endorsement, GPTM 100-AR 1221 item II which deletes and replaces Item 6 CANCELLATION AND NONRENEWAL, part.c.: i. Fraud or material misrepresentation made by you or with your knowledge in obtaining the policy, continuing the policy or in presenting a claim under the policy. ii. The occurrence of a material change in the risk that substantially increases any hazard insured against after policy issuance. iii. Violation of any local fire, health, safety, building, or construction regulation or ordinances with respect to any insured property or the occupancy of the property that substantially increases any hazard insured against under the policy. iv. A material violation of a material provision of the policy. GPTM 100-AR 1221 was approved in SERFF Filing # XLAM-133082668.</s> |
<s>[INST]<<SYS>>Review this pet insurance filing.
Company: Independence American Insurance Company
Product: PetsBest 2023 New Forms
State: Arkansas
Date: 04/07/2023
Description: Filing Description: RE: Independence American Insurance Company NAIC # 26581 Individual Pet Insurance forms Form NameForm Title IAIC-PB10001-ACCAccident Only Policy IAIC-PB10001-ILLAccident and Illness Policy IAIC-PB10001-WLLWellness Rider IAIC-PBI0002-DEC Declarations Page We are filing the above forms for review and approval. These forms are new and do not replace any previously filed forms. The corresponding rate filing has been submitted under SERFF ID# IAIC-133628079. This filing does not contain any unusual or possible controversial items from industry standards. To the best of our knowledge, this filing is complete and intended to comply with the insurance laws of your state. The Company appreciates the Department’s time and consideration in the review of this filing. Thank you, Diane Marlowe Sr. Compliance Specialist Independence American Insurance Company Independence Pet Group 602-834-0776 telephone
<</SYS>>
Generate an objection to this filing.[/INST]
The reasons for cancellation must comply with Arkansas Code Annotated §23-66-206 (15). Additionally, 20-days notice must be given for reasons other than non-payment of premium. The language in these forms does not appear to comply with our statutes. Please remove the "increasing your coverage 4(A)(2).</s><s>[INST]Generate a response to this objection.[/INST]Current policyholders who elect to increase coverages by increasing limits or adding supplementary benefits are indicating a material change in their level of risk sharing with the insurance company. The proposed language in the policy form is effectively giving the insurance company the opportunity to re-underwrite these new sets of risks. Our understanding of state law (Arkansas Code Annotated §23-66-206) is that policy cancellations are permitted for six reasons, the third of which is: (iii) The occurrence of a material change in the risk that substantially increases any hazard insured against after policy issuance This action is initiated by the policyholder, not Pets Best or the insurance company. If the policyholder does not change the insurance limit or supplementary benefits elected, the policy will remain in force.</s><s>[INST]Generate another objection to this filing.[/INST]Please explain why 4 (A) (2) requires a policy to be cancelled and re-written if coverages are increased.</s><s>[INST]Generate a response to this objection.[/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 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]Generate another objection to this filing.[/INST]Please amend the submitting a claim information to include the customer care center phone number.</s><s>[INST]Generate a response to this objection.[/INST]Please see attached Amendatory Endorsement which will be attached and made a part of the policy form.</s><s>[INST]Responses that refer to PDF attachments or similar are not useful.[/INST]Acknowledged.</s><s>[INST]Generate another objection to this filing.[/INST]Please explain why the base policy must be cancelled if this endorsement is cancelled.</s><s>[INST]Generate a response to this objection.[/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]Generate another objection to this filing.[/INST]Please refer to Bulletin 4A-2020, the contact information for the Arkansas Consumer Services Division must be included in the policy.</s><s>[INST]Generate a response to this objection.[/INST]Please see attached Amendatory Endorsement which will be attached and made a part of the policy form.</s><s>[INST]Responses that refer to PDF attachments or similar are not useful.[/INST]Acknowledged.</s> |
<s>[INST]<<SYS>>Review this pet insurance filing.
Company: Independence American Insurance Company
Product: 2023 VERSION 4
State: Arkansas
Date: 05/03/2023
Description: Filing Description: In conjunction with the United States Fire Insurance Company, the Independence American Insurance Company (the Company) is filing to transition the underwriting of it's pet medical program. No other changes to the rates, rules, forms or benefits are being requested.
<</SYS>>
Generate an objection to this filing.[/INST]
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.</s><s>[INST]Generate a response to this objection.[/INST]Policy changes requiring termination of an existing policy would be initiated by the policyholder. Attached is a list of all states/filings which have approved the Policy Changes section of the policy form; states not listed do not require filing or approval of policy forms. Additional approved competitor filing in AR is under ICCC-133596572 citing similar language.</s><s>[INST]Generate another objection to this filing.[/INST]The endorsement completely deletes and replaces the "When We Cancel" provision. The language in the endorsement does not comply with ACA 23-66-206(15). Cancellation due to any reason other than non-pay must receive 20-days notice, even if the policy has been in effect less than 60-days. . Non-payment may be for 10-days. Please correct the endorsement.</s><s>[INST]Generate a response to this objection.[/INST]The form has been updated to reflect the proper notice time.</s><s>[INST]Generate another objection to this filing.[/INST]Please explain what changes result in new enrollment, terminating the existing policy and implementing new waiting periods.</s><s>[INST]Generate a response to this objection.[/INST]Due to the expanded risk, an increase in policy limits, a change from Accident only to Accident/Illness, or a mid-term change in deductible, would be subject as a cancel/rewrite (new enrollment) and therefore normal policy conditions apply. Such situations are not automatic, and the customer would be advised of the situation before making the decision to move forward.</s><s>[INST]Generate another objection to this filing.[/INST]The cancellation provision does not comply with ACA 23-66-206 (15).</s><s>[INST]Generate a response to this objection.[/INST]We have amended the form to be in compliance with ACA 23-66-206 (15).</s> |
<s>[INST]<<SYS>>Review this pet insurance filing.
Company: Trisura Insurance Company
Product: Pet Health Insurance
State: Arkansas
Date: 05/19/2023
Description: Filing Description: Attached is a Filing Authorization Letter from Trisura Insurance Company (hereinafter referred to as the Company) authorizing Martin & Company to submit this filing on their behalf. This filing will be used exclusively for Thorson Specialty Insurance Services Pet Health Insurance Program written through Trisura Insurance Company. Please direct all correspondence regarding this filing to Martin & Company. The Company is submitting independent forms for use with its new Pet Health Insurance Program. The proposed forms are based on what was filed by Clear Blue Insurance Company. Please be advised that the forms contained in this filing are system-generated and may be formatted differently due to system constraints. The content, however, will remain the same. Therefore, the forms will not be re-filed unless otherwise requested by your Department in response to this filing. Also, please be advised that variable fields are shown in brackets. The bracketed fields will be populated with the respective information, which is administrative in nature. The variable information may be subject to change and does not have an impact on the overall coverage provided by the policy.
<</SYS>>
Generate an objection to this filing.[/INST]
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.</s><s>[INST]Generate a response to this objection.[/INST]We have created and attached amendatory endorsement, TRSA-OPI-PC138-ILL-SAEN-AR, to be used with the Illness Policy.</s><s>[INST]Generate another objection to this filing.[/INST]The form name under the form schedule tab reads "Arizona" This is an Arkansas form.</s><s>[INST]Generate a response to this objection.[/INST]The form name has been amended to Arkansas.</s> |
<s>[INST]<<SYS>>Review this pet insurance filing.
Company: Trisura Insurance Company
Product: Pet Health Insurance
State: Arkansas
Date: 05/23/2023
Description: Filing Description: Attached is a Filing Authorization Letter from Trisura Insurance Company (hereinafter referred to as the Company) authorizing Martin & Company to submit this filing on their behalf. This filing will be used exclusively for Norse Specialty Insurance Services Program written through Trisura Insurance Company. Please direct all correspondence regarding this filing to Martin & Company. The Company is submitting independent rates and rules for use with its new Pet Health Insurance Program. The proposed rates and rules are based on what was filed by Clear Blue Insurance Company.
<</SYS>>
Generate an objection to this filing.[/INST]
Thorson Specialty Insurance Services does not appear to be licensed as an agency ore MGA in Arkansas. Please explain.</s><s>[INST]Generate a response to this objection.[/INST]A PSU has been submitted. Thorson has changed its name to Norse Specialty Insurance Services.</s><s>[INST]Generate another objection to this filing.[/INST]Please amend the trend note to specifically reference "Arkansas". The effective date information included in the note should be removed. The trend factor in Arkansas must always be 1.00.</s><s>[INST]Generate a response to this objection.[/INST]The manual has been amended.</s> |
<s>[INST]<<SYS>>Review this pet insurance filing.
Company: National Casualty Company
Product: Pet Insurance Plans
State: Arkansas
Date: 06/12/2023
Description: Filing Description: National Casualty Company (NCC) is submitting for your approval revisions to our existing rates and rules for our Percent of Invoice - Plan A. The Percent of Invoice - Plan A covers eligible expenses for veterinary services incurred for the prevention, diagnosis and treatment of injuries and illnesses in canine, feline, avian, reptile, rabbit, ferret, and other exotic pets with a choice of deductible and co-insurance options. We are requesting that this filing apply to all new business policies written effective on or after August 3, 2023, and all renewal policies effective on or after September 28, 2023, or within 90 days of the date of approval.
<</SYS>>
Generate an objection to this filing.[/INST]
Please cap individual increases at 40%.</s><s>[INST]Generate a response to this objection.[/INST]Individual increases have been capped at 40%. Please see the updated filing packet and RF-1 Exhibit.</s><s>[INST]Responses that refer to PDF attachments or similar are not useful.[/INST]Acknowledged.</s><s>[INST]Generate another objection to this filing.[/INST]Please clarify what is represented by the chart labeled Proposal $ Rate Impact, supporting exhibit 5, page 2.</s><s>[INST]Generate a response to this objection.[/INST]The chart labeled Proposal $ Rate Impact represents the dislocation by dollar amount in thousands to our policies in force. For example, 35 policies in force are seeing between a $100 and $200 increase.</s> |
<s>[INST]<<SYS>>Review this pet insurance filing.
Company: American Modern Home Insurance Company
Product: Pet Insurance Program
State: Arkansas
Date: 06/26/2023
Description: Filing Description: American Modern Home Insurance Company presents revisions to our currently approved Pet Insurance Program. Please see the Explanatory Memorandum under the Supporting Documentation for complete details.
<</SYS>>
Generate an objection to this filing.[/INST]
Please amend the renewal effective date to 12/22/2023.</s><s>[INST]Generate a response to this objection.[/INST]The effective date will be updated to 12/22/2023 via a post submission update, as well as the rate information on the rate/rule schedule tab. As a result of the updated effective date, the indication has been updated accordingly. With the new indication, there was a slight change in our proposed impact. The Accident & Illness and Accident Only Base Rates have been updated as well. Please see the updated filing and filing support attached.</s><s>[INST]Responses that refer to PDF attachments or similar are not useful.[/INST]Acknowledged.</s><s>[INST]Generate another objection to this filing.[/INST]Please amend the 5-year history section to include the most recent 5-years of data, even though there may not have been a rate change for the year.</s><s>[INST]Generate a response to this objection.[/INST]The 5-year history section within the NAIC Loss Cost Data Entry document has been updated to include the most recent 5 years of data. For the two years we did not have a rate change, No Rate Change is listed.</s><s>[INST]Generate another objection to this filing.[/INST]Please provide additional supporting documentation for the changes to the pet age and new territory factors. Additionally, explain the reasoning behind the selected age factors.</s><s>[INST]Generate a response to this objection.[/INST]Underwriting Age and Tenure -Additional analysis was completed on the Underwriting Age and Tenure proposed factors for both dogs and cats. Based on the indications, the older age pets are being subsidized by the younger pets too significantly, where we believe it would impact new business negatively. A minimum of a +8.0% rate increase was selected for every tenure increase. By taking rates earlier in the pet's tenure it allows us to reduce the rate increases we have to push through to the policyholder later in the pet's life, increasing retention and customer satisfaction. The minimum of 8% was selected as these customers would also get the 'healthy pet discount', reducing the increase to ~3%, which is manageable from a customer experience perspective, but also gives us continued positive premium drift. Territory -To leverage the countrywide data that our GLM has in modeling territory, we used the indications from geodemographic components of the GLM to provide guidance in the territory definition process as well as providing support for the selected indications. Indications are calculated for each zip-code by scoring up the geodemographic components. Zip-codes with similar indications are grouped together. The final territory indications are the averages across zip-codes within each territory weighted by the earned exposures. There are three geo-demographical variables used in this iteration: the proportion of the population which is at least 25 and has a bachelor degree, the median rent for the housing, and the population density within a zip code. These variables were selected on the basis of their robustness in predictive power prospectively.</s><s>[INST]Generate another objection to this filing.[/INST]Please provide the manual page for territory definitions.</s><s>[INST]Generate a response to this objection.[/INST]Please see the attached Arkansas Territory Definitions.</s><s>[INST]Responses that refer to PDF attachments or similar are not useful.[/INST]Acknowledged.</s><s>[INST]Generate another objection to this filing.[/INST]Please confirm that individual increases will be capped at 35%.</s><s>[INST]Generate a response to this objection.[/INST]There were no changes to the Renewal Transition Plan rule with this filing effort. Yes, any rate change resulting in a premium increase greater than 35% will be capped. Any changes in exposure or to pet risk characteristics will not be subject to the capping rule.</s> |
<s>[INST]<<SYS>>Review this pet insurance filing.
Company: Metropolitan General Insurance Company
Product: 2023 Pet Rate Change Filing
State: Arkansas
Date: 05/09/2023
Description: Filing Description: This is a rate filing to present revised rate materials, for approval, for Metropolitan General Insurance Company’s currently approved pet insurance products. The rate filings were approved on May 19, 2021, under SERFF Tracking Number: META- 132823217 and on August 29, 2022, under SERFF Tracking Number: META-133376134. These revised rates are based on a review of historical data for policies by Metropolitan General Insurance Company. While we have separate policies for exotic pets and cat/dog coverage, we have combined the rate materials for these policies due to similarity in rating. The rate manual and actuarial memorandum included in this filing will apply to new policies issued as well as renewals of in force policies. If you have any questions or concerns regarding the enclosed materials, please let us know. Thank you for your attention to this matter. Vincent Li AVP & Pricing Actuary
<</SYS>>
Generate an objection to this filing.[/INST]
All request for rate changes submitted to the Department must include supporting data as required by Arkansas Code Annotated § 23-67-209 and Rule 23, Section 7.A.2. Explain the consideration given to all investment income attributable to premiums and to the reserves associated with those premiums and to loss reserve funds. Explain or provide supporting documentation for the 10% trend assumption. Provide the actual data referenced in the memo for each change that has been "derived based on the claims experience of policies administered by MetLife". We understand that 5-year's experience is not available for Arkansas since the program was implemented in 2021, however, the increases proposed in this filing are too significant to allow without sufficient data to support them.</s><s>[INST]Generate a response to this objection.[/INST]Response: Pet Insurance is an annually renewable term product that does not require the long-term reserves that are typical of other Property & Casualty Products. The income generated from the positive cash flow and reserves is expected to be 0.3% of premium. Please see attached Trend Support 20230712 for the documentation for the 10% trend assumption. Please see the Factor Support Exhibit AR 20230712 for all the data documenting each change referenced in the memo.</s><s>[INST]Responses that refer to PDF attachments or similar are not useful.[/INST]Acknowledged.</s><s>[INST]Generate another objection to this filing.[/INST]A capping rule must be included in the manual.</s><s>[INST]Generate a response to this objection.[/INST]Response: Please see attached manual with rate capping language from the actuarial memo. Please note weve also provided a revised actuarial memo with a 8/4/23 effective date.</s><s>[INST]Generate another objection to this filing.[/INST]Please provide examples demonstrating the circumstances under which the minimum premium rule will actually apply using AR rates. The application of 5% and 10% appears unnecessary given the application of the family plan factors applied.</s><s>[INST]Generate a response to this objection.[/INST]Response: See attached Family Plan Premium Example 20230712 for an example of how the family plan minimum premium calculation works. When a low premium and high premium pet are combined into a family plan, it is possible that the combined total premium for the family plan is less than the premium on the high premium pet alone. In this example pet 1 is a 1 year old mixed breed cat under 20 pounds and pet 2 is a 5 year old Doberman dog over 70 pounds. You can see the premium calculated for each individually is $40.29 and $205.80. However, when combined into a family plan the total premium calculated is $170.58 which is lower than the individual premium of $205.80 for the older dog. This example is why this minimum premium formula is necessary. </s><s>[INST]Generate another objection to this filing.[/INST]All request for rate changes submitted to the Department must include supporting data as required by Arkansas Code Annotated § 23-67-209 and Rule 23, Section 7.A.2. Rate changes are not acceptable without sufficient justification.</s><s>[INST]Generate a response to this objection.[/INST]Please see page 1 of Rate Increase Support Exhibit AR.</s><s>[INST]Responses that refer to PDF attachments or similar are not useful.[/INST]Acknowledged.</s><s>[INST]Generate another objection to this filing.[/INST]Please explain the minimum premium note on the rating formula page.</s><s>[INST]Generate a response to this objection.[/INST]The minimum premium is meant for family plans with more than 1 pet. It is to ensure that adding another pet to the plan will increase the premium. In a small number of cases, adding a pet can lead to a decrease in overall premium without this formula.</s><s>[INST]Generate another objection to this filing.[/INST]Provide statistical documentation supporting the distribution channel factors.</s><s>[INST]Generate a response to this objection.[/INST]Please see page 2 of Rate Increase Support Exhibit AR. </s><s>[INST]Responses that refer to PDF attachments or similar are not useful.[/INST]Acknowledged.</s><s>[INST]Generate another objection to this filing.[/INST]Provide details regarding the rate cap of 4x.</s><s>[INST]Generate a response to this objection.[/INST]Renewal rates will be capped for 1 year at 40% and then will go to the full filed rate. This has been updated in the actuarial memo.</s><s>[INST]Generate another objection to this filing.[/INST]Maximum increase amounts appear excessive. Please provide a histogram detailing the number of policies and the impact percentages. Indicate the changes in this filing impacting each policy receiving increases over 50%.</s><s>[INST]Generate a response to this objection.[/INST]See Rate Dislocation Histogram AR PDF for a histogram detailing policies and impact percentages. The change driving increases greater than 50% are increased rates to covered percentages of 90% to 100%</s> |
<s>[INST]<<SYS>>Review this pet insurance filing.
Company: American Pet Insurance Company
Product: Aflac Pet Insurance Powered by Trupanion
State: Arkansas
Date: 07/18/2023
Description: Filing Description: American Pet Insurance Company is filing to propose the following changes: Base rates: Revising based on experience Pet Owner Support Rates: Adding this option with updated utilization assumption
<</SYS>>
Generate an objection to this filing.[/INST]
Apparently there was an error in SERFF for the link to the form. Please complete the attached. I apologize for the inconvenience.</s><s>[INST]Generate a response to this objection.[/INST]The completed documents have been attached.</s><s>[INST]Generate another objection to this filing.[/INST]This form is required with all rate change filings. It is not just for loss cost filings.</s><s>[INST]Generate a response to this objection.[/INST]Thank you. The documents have been added to the filing.</s> |
<s>[INST]<<SYS>>Review this pet insurance filing.
Company: Metropolitan General Insurance Company
Product: 2023 Pet Rate Change Filing
State: Arizona
Date: 05/11/2023
Description: Filing Description: This is a rate filing to present revised rate materials, for approval, for Metropolitan General Insurance Company’s currently approved pet insurance products. The rate filings were approved on September 16, 2021, under SERFF Tracking Number: META-132980070 and on August 25, 2022 under SERFF Tracking Number: META-133376155. These revised rates are based on a review of historical data for policies by Metropolitan General Insurance Company. While we have separate policies for exotic pets and cat/dog coverage, we have combined the rate materials for these policies due to similarity in rating. The rate manual and actuarial memorandum included in this filing will apply to new policies issued as well as renewals of in force policies. If you have any questions or concerns regarding the enclosed materials, please let us know. Thank you for your attention to this matter. Thank you, Vincent Li, AVP & Pricing Actuary
<</SYS>>
Generate an objection to this filing.[/INST]
In regards to the support for the discounts; 0.7% difference in loss ratios does not appear to support the discounts being proposed. [PC0206]</s><s>[INST]Generate a response to this objection.[/INST]Response: The company respectfully believes the minimal 0.7% difference in loss ratios supports the discounts. Please note this loss ratio data includes discounts already active in the marketplace. If policyholders with discounts had loss ratios significantly lower than those without, this would suggest discounts should be larger than they currently are.</s><s>[INST]Generate another objection to this filing.[/INST]Discount/Affinity programs-actuarial justification not provided. The Department requests actuarial support for discounts. The product provides discounts to specific group, specifically, discounts for policyholders that meet specific criteria are being offered. The specific discounts that we are seeking support of are: Affinity Group Program Discount Strategic Relationship Discount Animal Care Discount Serving Military, Veteran, 1st Responder and Healthcare Workers Discount Multi-Policy Discount The Department is not seeking to disapprove or reject the filing. We are seeking quantitative reasoning for the use of discounting practices. It is assumed that your company would validate the relativity of discounts, and could provide loss ratio data displaying the justification for said discounts. ***If this data has already been provided by the company/companies referenced in the filing (e.g. under each company code) in the last year, please reference the AZ SERFF filing number in a brief response. Please provide this information specific to the company and its loss experience. This justification should be in the form of tables displaying comparisons of loss ratios between policyholders receiving the discount and those that are not. While Arizona specific data is preferred, National data to support discounts is acceptable. Per ARS 20-383 (D) allows affinity groups (aka Mass Marketing) if the rates for the Affinity Groups are supported by actual differences in expenses or risks compared to other insureds. Please provide the prior SERFF filing number for the supporting documentation to support these discounts and/or the supporting documentation for the addition of new groups.[PC0248]</s><s>[INST]Generate a response to this objection.[/INST]Response: National data is used over Arizona to increase credibility. Discounts have been available countrywide, and the company is able to validate the relativity of discounts based on recent experience. As can be seen in the loss ratio table below, loss ratios are flat. This suggests discounts are actuarially sound. Paid Loss Ratio No Discount/ 85.8% Discount(s) / 85.1% Total / 85.4%</s><s>[INST]Generate another objection to this filing.[/INST]Does not include any supporting documentation for the fees shown in the rule page. Must include an exhibit of expenses for each of the fees shown. [PC0160]</s><s>[INST]Generate a response to this objection.[/INST]Response: Please see attached Exhibit - MetLife Fee Support for the requested information.</s> |
<s>[INST]<<SYS>>Review this pet insurance filing.
Company: United States Fire Insurance Company
Product: PET - V4.4
State: California
Date: 10/05/2021
Description: Filing Description: The United States Fire Insurance Company (the Company) is filing to make the following changes to its pet medical program: -Overall rate revision of +4.4%. -Revision of the annual limit factors. -Breed factor adjustments -Revision of the age factors. -Coverage modules. -Addition of five new forms to coincide with the Coverage Modules. -Inclusion of first responders with the military discount. -Updated rating algorithm to accommodate coverage modules. -Removal of the underwriting section from the rate manual. -Withdrawal of the Knee Ligament Exclusion; this form was never utilized and will not have customer impact. -Introduction of 5 new forms associated with the new Coverage Modules -Updates to the Declarations page to incorporate the Coverage Module options, as well as clarifications -Update to the Accident/Illness Coverage for clarifications
<</SYS>>
Generate an objection to this filing.[/INST]
The form listed on page 9 of Rate Application and the forms listed under the form Tab is inconsistent. Please verify. If SERFF is wrong, withdraw the unnecessary forms and then resubmit If the application is wrong, please revise it.</s><s>[INST]Generate a response to this objection.[/INST]Page 9 of the Rate Application form tab has been updated to include all forms in the filing.</s><s>[INST]Generate another objection to this filing.[/INST]As required, submit the clean copy and a marked-up copy of all the current (previously approved) forms. See page 10 of our filing instructions for additional information.</s><s>[INST]Generate a response to this objection.[/INST]The clean and marked-up copies of all current forms have been uploaded.</s><s>[INST]Generate another objection to this filing.[/INST]Submit the required exhibits as listed on page 3 of the Rate Application and in our filing instructions. Exhibits 2, 3, 4, 6, 9, 10, 11, 12, 14, 15, 20, and 21 must be in both working Excel (with formulas intact) and PDF (with searchable text) formats.</s><s>[INST]Generate a response to this objection.[/INST]The required exhibits have been uploaded.</s> |
<s>[INST]<<SYS>>Review this pet insurance filing.
Company: American Pet Insurance Company
Product: Pets Best Inc. Pet Health Insurance
State: California
Date: 03/28/2022
Description: Filing Description: American Pet Insurance Company (APIC) is filing to introduce updated base rates and rating factors. Overall Rate Impact: +11.4% Proposed Effective Date: 7/2/2022 for new business and renewals Base Rates: Revising based on experience and in consideration of other proposed changes Coinsurance and Deductible Factors: Revising based on experience.
<</SYS>>
Generate an objection to this filing.[/INST]
Please address the following completion errors and data discrepancies noted below: GENERAL COMPLETION AND RECONCILIATION 1. Excluded expense data is available for the 2021 year. Please update tabs '4.1Excluded Exp' and '4.2Excluded Exp' of the rate template with data from years 2019, 2020, and 2021. RATE TEMPLATE AND STANDARD EXHIBITS COMPLETION AND RECONCILIATION 1. Trended On-Level Premium (Adjusted Earned Premium) does not match between Application Page 4 and Rate Template 7.1. 2. Calendar Year Earned Premium does not match between Application Page 5 and Exhibit 5 for years 20184, 20194, and 20204. 3. Please enter data in the Paid Losses & DCCE triangle (Exhibit 7) of the Standard Exhibits Template for this coverage/form/program. 4. Please enter data in the Paid DCCE triangle (Exhibit 7) of the Standard Exhibits Template for this coverage/form/program. 5. Please enter data in the Incurred Losses & DCCE triangle (Exhibit 7) of the Standard Exhibits Template for this coverage/form/program. 6. Please enter data in the Incurred Losses triangle (Exhibit 7) of the Standard Exhibits Template for this coverage/form/program. 7. Please enter data in the Incurred DCCE triangle (Exhibit 7) of the Standard Exhibits Template for this coverage/form/program. 8. Please enter data in the Closed With Payment Claim Counts triangle (Exhibit 7) of the Standard Exhibits Template for this coverage/form/program. 9. Please enter data in the Closed Wtih No Payment Claim Counts triangle (Exhibit 7) of the Standard Exhibits Template for this coverage/form/program. 10. On-Level/CRL Adjustment Factors does not match between Rate Template 6.1 and what I calculated using the geometric (i.e. parallelogram/squares) method for year 20214. 11. On-Level/CRL Factors does not match between Exhibit 5 and what I calculated using the geometric (i.e. parallelogram/squares) method for the following quarters: 20171, 20172, 20192, 20193, 20194, 20201, 20202, 20204, 20211, 20212, 20213. 12. Annual Paid Losses does not match between Exhibit 7 (Converted) and Exhibit 8 for the following years: 20174, 20184, 20194, 20204, 20214. SERFF Tracking #: APII-133205603 State Tracking #: 22-824 Company Tracking #: APIC-PBI-20220702-R State: California Filing Company: American Pet Insurance Company TOI/Sub-TOI: 09.0 Inland Marine/09.0004 Pet Insurance Plans Product Name: Pets Best Inc. Pet Health Insurance Project Name/Number: / PDF Pipeline for SERFF Tracking Number APII-133205603 Generated 11/21/2022 11:56 PM 13. Annual Reported Claim Counts does not match between Exhibit 7 (Converted) and Exhibit 8 for the following years: 20174, 20184, 20194, 20204, 20214. 14. Losses (DCCE included) does not match between Rate Template 6.1 and Exhibit 7 for year 20214. 15. Loss Development Factors does not match between Rate Template 6.1 and Exhibit 7 (Quarterly) for year 20214. 16. For Premium Trend (Exhibit 5) and Loss Trend (Exhibit 8), justify the decision for selecting the 12 point trend. Explain why the 12 point selection is the most actuarially sound. 17. For Loss Development (Exhibit 7), justify the decision for selecting ultimate incurred loss and DCCE.</s><s>[INST]Generate a response to this objection.[/INST]Please see responses attached under Supporting Documentation named "Responses to Objections Received June 27, 2022".</s><s>[INST]Responses that refer to PDF attachments or similar are not useful.[/INST]Acknowledged.</s><s>[INST]Generate another objection to this filing.[/INST]Please address the following completion errors and data discrepancies noted below: 1. Cash does not match between tab '3.2YieldFIT' of the rate template and our records for American Pet Ins Co (NAIC code 12190). 2. Please make an Ultimate Loss selection for every coverage/form/program you have filed for in tab '3.Exhibit 7 - Annual' of the Standard Exhibits Template. 3. What unit (reported claims, closed claims, paid claims, etc.) is being counted for historical experience credibility?</s><s>[INST]Generate a response to this objection.[/INST]Please see "Responses to Objections Received May 17, 2022" attached on the Supporting Documentation tab. Thank you.</s><s>[INST]Responses that refer to PDF attachments or similar are not useful.[/INST]Acknowledged.</s><s>[INST]Generate another objection to this filing.[/INST]Certain element(s) of your rate filing raise(s) questions as to whether those elements affects rates so as to make them excessive, inadequate, unfairly discriminatory or otherwise in violation of applicable provisions of the California Insurance Code or California Code of Regulations or our Filing Instructions. In order to continue a proper review of your filing, we have determined that the following additional information is required: 1) Who comprises the members of the group and how would a prospective risk be eligible for group membership? 2). Please submit the comprehensive support as to why the group deserves its proposed rate. 3). If the rate support is based on expense savings, how exactly do these expense savings work and why would the expenses differ between those who are members of the group and those that are not members of this group? When an insurance rate application is not approved, the Commissioner is required by California Insurance Code §1861.05 et seq, (Amended by Stats.1992 AB2875), to issue a NOTICE OF HEARING within 60 days of the date of public notice. Without the additional information requested above, we will be unable to consider your application for approval. Please submit the requested information on or before the date noted above or, should you need additional time to provide the requested information, you may withdraw the file and resubmit at a later date.</s><s>[INST]Generate a response to this objection.[/INST]Please see responses on the Supporting Documentation tab, "APIC Product Grid" and "Responses to Objections Received May 4, 2022". Thank you.</s><s>[INST]Responses that refer to PDF attachments or similar are not useful.[/INST]Acknowledged.</s><s>[INST]Generate another objection to this filing.[/INST]Provide the most recent applicable CDI file number in this line, subline and/or program and, if applicable, the program name on page 1, row 36 of the application. See error warning on column L. Please always provide this on all your filings except for new programs. If this is a group filing, provide the latest applicable CDI file number for each company. For forms-only filings, the CDI number we need is of the latest prior approved new program, rate change or rule change filing that contains your current rates. We review forms to determine the rate impact of the form. If we do not know which rates apply to the form we cannot do this review. SERFF Tracking #: APII-133205603 State Tracking #: 22-824 Company Tracking #: APIC-PBI-20220702-R State: California Filing Company: American Pet Insurance Company TOI/Sub-TOI: 09.0 Inland Marine/09.0004 Pet Insurance Plans Product Name: Pets Best Inc. Pet Health Insurance Project Name/Number: / PDF Pipeline for SERFF Tracking Number APII-133205603 Generated 11/21/2022 11:56 PM If you do not have a prior filing for this program and if it is a stand-alone program, please withdraw and then refile it as New Program type filing.</s><s>[INST]Generate a response to this objection.[/INST]The CDI number has been added to the application.</s><s>[INST]Generate another objection to this filing.[/INST]Address the error/warning on page 4 of the application. See error/warnings on column G.</s><s>[INST]Generate a response to this objection.[/INST]The error/warning has been resolved.</s><s>[INST]Generate another objection to this filing.[/INST]Rate Template: 1) Fill out page 3.1 completely. 2) Provide the Institutional Total Advertising on page 4.1, row 41. 3) Provide the countrywide direct earned premium on page 4.1, row 11</s><s>[INST]Generate a response to this objection.[/INST]There is no additional information to add on these exhibits. We have added zeros in the blank boxes.</s><s>[INST]Generate another objection to this filing.[/INST]The company tracking number on the Affidavit and on SERFF do not match. Please revise and resubmit . Please note that "Company Tracking Number" is the "Co Tr Num" listed on SERFF to identify the application.</s><s>[INST]Generate a response to this objection.[/INST]The Affidavit has been updated to include the corresponding Company Tracking Number listed on SERFF to identify the application.</s><s>[INST]Generate another objection to this filing.[/INST]Submit Exhibits 2, 3, 6, 9, 11, 12, 14, and 21 in both working Excel (with formulas intact) and PDF (with searchable text) format.</s><s>[INST]Generate a response to this objection.[/INST]Excel files are being submitted, but there are no formulas in any of these exhibits.</s><s>[INST]Generate another objection to this filing.[/INST]Please submit Exhibit 1 with all the required information indicated on Page 25 of the Filing Instructions. If any of the required information is not applicable, please explain why in Exhibit 1.</s><s>[INST]Generate a response to this objection.[/INST]All approved Form and Rule filings have also been added to Exhibit 1 as indicated in the instructions.</s> |
<s>[INST]<<SYS>>Review this pet insurance filing.
Company: American Pet Insurance Company
Product: Trupanion Pet Health Insurance Product
State: California
Date: 04/30/2021
Description: Filing Description: American Pet Insurance Company is filing to propose the following changes: Base Rates: Revising based on experience Geographical Factors: Revising based on experience Breed Factors: Revising based on experience
<</SYS>>
Generate an objection to this filing.[/INST]
Certain element(s) of your rate filing raise(s) questions as to whether those elements affects rates so as to make them excessive, inadequate, unfairly discriminatory or otherwise in violation of applicable provisions of the California Insurance Code or California Code of Regulations or our Filing Instructions. In order to continue a proper review of your filing, we have determined that the following additional information is required: 1) Who comprises the members of the group and how would a prospective risk be eligible for group membership? 2). Please submit the comprehensive support as to why the group deserves its proposed rate. 3). If the rate support is based on expense savings, how exactly do these expense savings work and why would the expenses differ between those who are members of the group and those that are not members of this group? When an insurance rate application is not approved, the Commissioner is required by California Insurance Code §1861.05 et seq, (Amended by Stats.1992 AB2875), to issue a NOTICE OF HEARING within 60 days of the date of public notice. Without the additional information requested above, we will be unable to consider your application for approval. Please submit the requested information on or before the date noted above or, should you need additional time to provide the requested information, you may withdraw the file and resubmit at a later date.</s><s>[INST]Generate a response to this objection.[/INST]Please see "Response to Objections Received May 4th,2022" and the "APIC Product Grid", on the supporting documentation tab.</s><s>[INST]Responses that refer to PDF attachments or similar are not useful.[/INST]Acknowledged.</s><s>[INST]Generate another objection to this filing.[/INST]Please correct the following completion errors and data discrepancies noted below: 1. Calendar Year Earned Premium does not match between Application Page 5 and Exhibit 5 for years 20184, 20194, and 20204. 2. Earned Premium does not match between Rate Template 6.1 and Exhibit 5 for year 20211.</s><s>[INST]Generate a response to this objection.[/INST]Please see updated files.</s><s>[INST]Responses that refer to PDF attachments or similar are not useful.[/INST]Acknowledged.</s><s>[INST]Generate another objection to this filing.[/INST]Please correct the following completion errors and data discrepancies noted below: 1. The following assets do not match between tab '3.2YieldFIT' of the rate template and our records for American Pet Ins Co (NAIC code 12190): Short-Term U.S. Government Bonds, Long-Term Other Taxable Bonds, Cash, Other, Investment Expense. 2. Tab '1.General' of the Standard Exhibits Template is incomplete.</s><s>[INST]Generate a response to this objection.[/INST]1. Please see updated numbers 2. Please see updated tab</s><s>[INST]Responses that refer to PDF attachments or similar are not useful.[/INST]Acknowledged.</s><s>[INST]Generate another objection to this filing.[/INST]Submit Exhibits 2, 3, 6, 9, 11, 12, 14, and 21 in both working Excel (with formulas intact) and PDF (with searchable text) format.</s><s>[INST]Generate a response to this objection.[/INST]The required exhibits have been uploaded.</s> |
<s>[INST]<<SYS>>Review this pet insurance filing.
Company: American Pet Insurance Company
Product: Trupanion for Chewy Health
State: California
Date: 04/29/2022
Description: Filing Description: American Pet Insurance Company (APIC) is filing to introduce a new pet health insurance program for Chewy Health. The insurance coverage is designed to provide reimbursement of medical expenses to owners of dogs and cats for illnesses and injuries.
<</SYS>>
Generate an objection to this filing.[/INST]
Certain element(s) of your rate filing raise(s) questions as to whether those elements affects rates so as to make them excessive, inadequate, unfairly discriminatory or otherwise in violation of applicable provisions of the California Insurance Code or California Code of Regulations or our Filing Instructions. In order to continue a proper review of your filing, we have determined that the following additional information is required: 1) Who comprises the members of the group and how would a prospective risk be eligible for group membership? 2). Please submit the comprehensive support as to why the group deserves its proposed rate. 3). If the rate support is based on expense savings, how exactly do these expense savings work and why would the expenses differ between those who are members of the group and those that are not members of this group? When an insurance rate application is not approved, the Commissioner is required by California Insurance Code §1861.05 et seq, (Amended by Stats.1992 AB2875), to issue a NOTICE OF HEARING within 60 days of the date of public notice. Without the additional information requested above, we will be unable to consider your application for approval. Please submit the requested information on or before the date noted above or, should you need additional time to provide the requested information, you may withdraw the file and resubmit at a later date.</s><s>[INST]Generate a response to this objection.[/INST]1). The members of group are Chewy members. A consumer may become a Chewy member by enrolling online at www.chewy.com. Although only available to eligible members of that group, this is an individually rated product. 2). As detailed in the APIC Product Grid and the updated underwriting manual submitted on May 18, 2022, each one of APICs programs have distinct product offerings. The same pet owner seeking insurance with Chewy could not receive these exact same benefits and coverages from any other APIC program. Key differences include: 100% coverage for Rx, supplements, and foods (subject to policy limits) purchased through Chewy.com; no maximum enrollment age; differences in waiting periods; connect with a vet telehealth services as well as differences in coverage such as coverage for exam fees, behavioral therapies, annual limits, and wellness benefits as a standalone product. For these reasons, this group deserves its proposed rate. 3). As discussed above, the difference is rates is a function of coverage offerings not expense savings.</s><s>[INST]Generate another objection to this filing.[/INST]Thank you for the above captioned application. Certain element(s) of your rate filing raise(s) questions as to whether those elements affects rates so as to make them excessive, inadequate, unfairly discriminatory or otherwise in violation of applicable provisions of the California Insurance Code or California Code of Regulations or our Filing Instructions. In order to continue a proper review of your filing, we have determined that the following additional information is required: Currently, the American Pet Insurance Company has the following approved pet insurance programs: PETS BEST HEALTH TRUPANION PET HEALTH INSURANCE PET HEALTH INSURANCE - AMERICAN KENNEL CLUB PET HEALTH INSURANCE - TRUPANION CA requires that insurers offer the lowest rate possible to any and all insureds who are qualified. Please submit a rating matrix that shows the proposed program will offer the lowest rate possible using the above approved programs' rating manuals as they apply to a risk sample for coverages that are similar in the programs. When an insurance rate application is not approved, the Commissioner is required by California Insurance Code §1861.05 et seq, (Amended by Stats.1992 AB2875), to issue a NOTICE OF HEARING within 60 days of the date of public notice. Without the additional information requested above, we will be unable to consider your application for approval. Kindly submit the requested information on or before the date noted above or, should you need additional time to provide the requested information, you may withdraw the file without jeopardy and resubmit at a later date.</s><s>[INST]Generate a response to this objection.[/INST]Thank you for your objection. We have included with this response a rate matrix to reflect APICs programs that are currently approved and on the market (Trupanion, Pets Best) and the two recently filed new APIC programs (Chewy, Aflac). As shown by this matrix, each product offering is unique to its program and each consumer is charged the lowest premium for their chosen product. In addition, certain products have restricted eligibility (e.g., Chewy is only available to Chewy members, Aflac is only available to employees whose employers offer Aflac Pet Insurance as an employee benefit). Further, we are simultaneously updating our underwriting manual to clarify the eligibility for the chewy product. Specifically, the underwriting manual now contains the following language: ELIGIBLE POLICYHOLDERS Only Chewy members are eligible to enroll in this policy. A consumer may become a Chewy member by enrolling online at www.chewy.com Please let us know if there is any additional information that we can provide at this time. As always, we will make ourselves available at your convenience if further discussion would be helpful to the Department in reviewing this filing.</s><s>[INST]Generate another objection to this filing.[/INST]Only (certificate-based) digital signatures created using Adobe Sign will be accepted. Please revise and resubmit the Affidavit.</s><s>[INST]Generate a response to this objection.[/INST]Please see the original affidavit attached.</s><s>[INST]Responses that refer to PDF attachments or similar are not useful.[/INST]Acknowledged.</s><s>[INST]Generate another objection to this filing.[/INST]Please address the WARNING Error Messages on the left on Page 2 of the Rate Template.</s><s>[INST]Generate a response to this objection.[/INST]Please see the updated Rate Template</s><s>[INST]Responses that refer to PDF attachments or similar are not useful.[/INST]Acknowledged.</s> |
<s>[INST]<<SYS>>Review this pet insurance filing.
Company: AXIS Insurance Company
Product: AH – Petplan – Wellness Endorsement
State: California
Date: 06/10/2022
Description: Filing Description: Attached, for your review, is a Filing Authorization Letter from AXIS Insurance Company (hereinafter referred to as the Company) authorizing Martin & Company to submit this filing on their behalf. Please direct all correspondence regarding this filing to Martin & Company. The company recently introduced its Petplan program in your jurisdiction that provides pet health insurance coverage. It now is introducing a new endorsement, Wellness and Preventive Care Coverage to expand the coverage offerings under this program. Please be advised the form is system-generated and may be formatted differently due to system constraints. The content, however, will remain the same. Therefore, the form will not be re-filed unless otherwise requested by your Department in response to this filing. Please be advised that variable fields are shown in brackets. The bracketed fields will be populated with the respective information, which is administrative in nature. The variable information may be subject to change and does not have an impact on the overall coverage provided by the policy. Please contact us if you have any questions or require additional information.
<</SYS>>
Generate an objection to this filing.[/INST]
Please submit the required documents listed on the Filing Checklist/Page 3 of the Rate Application. 1. Complete Printed Rate and Rule Manual Pages 2 Underwriting Guidelines</s><s>[INST]Generate a response to this objection.[/INST]1. Please see the Form Usage Rules (PP-WP-2021-10) attached under the Rate/Rule Schedule tab. 2. Exhibit 18 is attached under the Supporting Documentation tab.</s><s>[INST]Responses that refer to PDF attachments or similar are not useful.[/INST]Acknowledged.</s><s>[INST]Generate another objection to this filing.[/INST]Submit Exhibits 2, 3, 4, 6, 9, 10, 11, 12, 14, 15, 20 and 21 in both working Excel (with formulas intact) and PDF (with searchable text) format.</s><s>[INST]Generate a response to this objection.[/INST]The Company has provided Excel versions of the exhibits. It did notice that in the XL Specialty filing that it is referencing, the CDI did not require Excel versions. The Company would also point out that many of these Excel spreadsheets have just verbiage and no calculations which would imply that Excel is not needed. Exhibit 21 does not apply to this submission as we understand it.</s><s>[INST]Generate another objection to this filing.[/INST]Please address the issue of "#div/0! error" on the proposed overall rate change on Page 4 of the Rate Application.</s><s>[INST]Generate a response to this objection.[/INST]The company has not written any premium under the program to date so the entries are correct in that there is no rate indication nor impact from the introduction of this endorsement.</s><s>[INST]Generate another objection to this filing.[/INST]The proposed rate impact is not provided on Page 2 of the Rate Template. Please address the "Error" message on the page.</s><s>[INST]Generate a response to this objection.[/INST]The company would direct you to its response to Objection #4.</s> |
<s>[INST]<<SYS>>Review this pet insurance filing.
Company: AXIS Insurance Company
Product: Pet Health
State: California
Date: 08/31/2022
Description: Filing Description: SERFF Tracking #: AXSS-G133380643 State Tracking #: 22-2210 Company Tracking #: PETPLAN-2021-12-0160-CA-R State: California Filing Company: AXIS Insurance Company TOI/Sub-TOI: 09.0 Inland Marine/09.0004 Pet Insurance Plans Product Name: Pet Health Project Name/Number: PETPLAN - 2022 Rate Revision/PETPLAN-2021-12-0160 PDF Pipeline for SERFF Tracking Number AXSS-G133380643 Generated 04/25/2023 11:46 P
<</SYS>>
Generate an objection to this filing.[/INST]
Rate Template: 1. Provide the institutional data on page 4.1. 2. Fill out page 4.2.</s><s>[INST]Generate a response to this objection.[/INST]Attached is the updated Rate Templated.</s><s>[INST]Generate another objection to this filing.[/INST]Please use the Affidavit template available on our website and in SERFF. Here is the link: http://www.insurance.ca.gov/0250-insurers/0800-rate-filings/0200-prior-approval-factors/upload/Affidavit.pdf SERFF Tracking #: AXSS-G133380643 State Tracking #: 22-2210 Company Tracking #: PETPLAN-2021-12-0160-CA-R State: California Filing Company: AXIS Insurance Company TOI/Sub-TOI: 09.0 Inland Marine/09.0004 Pet Insurance Plans Product Name: Pet Health Project Name/Number: PETPLAN - 2022 Rate Revision/PETPLAN-2021-12-0160 PDF Pipeline for SERFF Tracking Number AXSS-G133380643 Generated 04/25/2023 11:46 PM</s><s>[INST]Generate a response to this objection.[/INST]Attached is the affidavit. </s><s>[INST]Generate another objection to this filing.[/INST]Exhibits: See page 33 of our Rate Filing Instructions. Insurers must submit tables in Exhibit 20 displaying customer dislocation in increments of 5%5 for all filings proposing a change of any type that results in a rate adjustment to any individual customer.</s><s>[INST]Generate a response to this objection.[/INST]Attached are the exhibits.</s><s>[INST]Generate another objection to this filing.[/INST]Please use the 06-27-2022 version of the Rate Application and Rate Template. . Here's our website link: http://www.insurance.ca.gov/0250-insurers/0800-rate-filings/0200-prior-approval-factors/</s><s>[INST]Generate a response to this objection.[/INST]Attached are the current versions of the Rate Application and Rate Template.</s><s>[INST]Generate another objection to this filing.[/INST]All filing now requires Affidavit. Insurers must submit an Affidavit confirming that the information filed is true, complete, and accurate for all filing submissions. Please note: 1) ONLY digital signatures with Adobe certificate-based signature, created using Adobe sign will be accepted. 2) The company tracking number stated on the Affidavit should be the same as the company tracking number used in SERFF. See page 3 of the 1-11-2022 version of the Rate Application and page 4 of the 1-11-2022 Filing Instructions for more information.</s><s>[INST]Generate a response to this objection.[/INST]Attached is the required affidavit.</s> |
<s>[INST]<<SYS>>Review this pet insurance filing.
Company: WESTCHESTER FIRE INSURANCE COMPANY
Product: 22-PIM-2021819
State: California
Date: 12/01/2022
Description: Filing Description: Westchester Fire Insurance Company (“the Company”) is filing a revision to its Pet Health program filed under the Inland Marine line of business and Pet Insurance Plan sub-line. There are three elements addressed with this filing. 1.Remove the medical trend factor per the California DOI. Also note that on February 10, 2022, the Monthly Base Loss Cost had been increased 3% per the approved medical trend factor in SERFF tracking number ACEH-132536766. 2.Increase the Monthly Base Loss Cost and Claims Fee Monthly Base Loss Cost by an additional 10% to reflect the increase in average claim costs. 3.Add 38 breeds and 5 zip codes that were missing from the rating manual (these are listed in the redline rating manual). The breeds were bucketed based on similar breeds that were previously in the rating manual. Zip codes were bucketed based on the rating territories of surrounding zip codes. Please see the attached exhibits as support for this rate increase. Note that Westchester Fire includes pets that were originally written in ACE American Insurance Company and Indemnity Insurance Company of North America but have been transitioned over. The indication is +26.0%. The impact of our proposed changes is 10.0%. There is no impact for adding breeds and zip codes. The “Number of Policyholders Affected” figure entered in the SERFF Rate Information section represents the number of pets in-force in September 2022. The “Written Premium for this Program” figure represents the annualized premium associated for these in-force pets. Please see our attached proposed rating manual and redlined version. The Company respectfully requests that the proposed rates and rules be implemented for all policies effective 06/01/2023.
<</SYS>>
Generate an objection to this filing.[/INST]
1. Please update the rate application, rate template and supporting exhibits to reflect the revised proposed rare change of 5%. 2. Please make sure that the program name is uniform between the rate application page 4 & 5, rate template and standard exhibits.</s><s>[INST]Generate a response to this objection.[/INST]Upon further consideration, we want to select a higher rate increase of 10% instead of 5% due to the indication of 28.2% and the fact that we arent going to hit the proposed effective date. Please see the revised state exception pages and revised rate rule filing schedule. We also updated the General Information tab as well.</s><s>[INST]Responses that refer to PDF attachments or similar are not useful.[/INST]Acknowledged.</s><s>[INST]Generate another objection to this filing.[/INST]1) Enter fees if they apply or select the check box indicating that no fees apply on page 8 of the application. See column G. 2) Fill out page 10 of the application.</s><s>[INST]Generate a response to this objection.[/INST]Please see our edited documents (the Rate Application and Exhibit 18).</s><s>[INST]Responses that refer to PDF attachments or similar are not useful.[/INST]Acknowledged.</s> |
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