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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>
<s>[INST]<<SYS>>Review this pet insurance filing. Company: Independence American Insurance Company Product: PetsBest 2023 Transferred Product Filing State: California Date: 02/10/2023 Description: Filing Description: We are submitting the attached forms and rates for your expedited review and approval. While these forms and rates are a new filing for Independence American Insurance Company (IAIC), they are identical to the forms and rates previously approved for use by American Pet Insurance Company (APIC) for use with the same managing general agent partner. APIC received approval as follows: •APII-130444494 – Initial form filing, approved on 01/13/2017 (included all forms except CA Amendatory Endorsement) •APII-131940518 – CA Amendatory Endorsement (not included in initial form filing), approved on 08/02/2019 •APII-133205603 – Rates/rating manual, approved on 11/21/2022 As discussed in our General Counsel's call with the CA Department on 01/27/2023, IAIC needs to receive approval of these forms and rates on or before 02/28/2023, as PetsBest is required to switch underwriting carriers for new business sales no later than 03/01/2023. These forms are identical to those approved for use by APIC, apart from the form numbers and references to the appropriate underwriting entity. Anything you can do to expedite approval would be appreciated. <</SYS>> Generate an objection to this filing.[/INST] Since several discounts have been removed, please update the rating examples.</s><s>[INST]Generate a response to this objection.[/INST]Please see the revised CA Rating Examples 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 update the application to remove endorsement form IAIC-PB10005-WP Waiting Endorsement. As this has been recently withdrawn by the company.</s><s>[INST]Generate a response to this objection.[/INST]As requested, we have removed the endorsement form from the New Prior Approval Rate Application. Updated excel and pdf versions have been added.</s><s>[INST]Generate another objection to this filing.[/INST]The company submitted this form as an optional elective company endorsement form. It appears to broaden coverage. 1.) What is the rate charge for this endorsement form? Please clarify where I may find it in the manual.</s><s>[INST]Generate a response to this objection.[/INST]This endorsement was a prerequisite for the Pets Best Veterinary Examination Program CAplus discount, which was previously removed in-line with the Departments guidance in our objection response due 4/24. As this discount is no longer part of the product, we would like to withdraw the corresponding endorsement IAIC-PBI0005-WP (02/2023), 02/2023, Endorsement/Amendment/Conditions, Waiver of Waiting Periods Endorsement (Form) as well.</s><s>[INST]Generate another objection to this filing.[/INST]The company listed the application form IAIC-PB10003-APP in the PARA. 1.) Please provide a copy of the application.</s><s>[INST]Generate a response to this objection.[/INST]The application form has been added to the Forms Schedule tab</s><s>[INST]Generate another objection to this filing.[/INST]Please remove the web-link partners discount as it is unfairly discriminatory to insureds that do not have online access.</s><s>[INST]Generate a response to this objection.[/INST]We have removed this discount as per the Departments guidance. Updated clean and marked-up rate pages reflecting this change are included. Please note that we have also removed an obsolete reference to the previously-removed CAPlus Vet Exam Program discount on page 5 of the rate pages.</s><s>[INST]Generate another objection to this filing.[/INST]1. Please provide a list of the strategic Partners. 2. What is the criteria needed to become a strategic partner?</s><s>[INST]Generate a response to this objection.[/INST]1. Current Strategic Partners Progressive Kraft Lake (Farmers, Toggle) Union Plus Synchrony 2. Pets Best must be the exclusive pet insurance offered by the partner. The partner also has contractual marketing and distribution commitments with Pets Best.</s><s>[INST]Generate another objection to this filing.[/INST]Please provide a marked-up copy of the rate pages.</s><s>[INST]Generate a response to this objection.[/INST]Please see the included marked-up versions of the original APIC documents. As we are not proposing any changes to breed or geography factors, and the original pages do not contain rate effective date or any company-specific information, there is no revision to the APIC PBI URM CA 20200430 - Table 2 Breed Factors or APIC PBI URM CA 20200430 - Table 1 Geography Factors files other than now including them in the basic rate page package instead of as separate documents.</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 Strategic Partners Discount: 1.) Who are the Strategic Partners? 2.) Why do they deserve a discount? 3.) If the 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?</s><s>[INST]Generate a response to this objection.[/INST]1) Strategic Partners are distribution and advertising partners that have a strategic marketing agreement with Pets Best. 2) and 3) These companies either market to their customer and audiences bases directly (if they are P&C licensed) or give Pets Best access to their customer or audience base (if they are not licensed). Pets Best would otherwise not have a direct communication or advertising channel to access these customers directly, thereby reducing our overall marketing and acquisition costs. In addition, this business has better-than-average loss experience.</s><s>[INST]Generate another objection to this filing.[/INST]Regarding Employer and Affinity Groups <1,000 Employees and 1000+ Employees discounts: 1.) Who are the employers and Affinity Groups? 2.) Why do they deserve the discounts? 3.) If the 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?</s><s>[INST]Generate a response to this objection.[/INST]1) Employers are companies that include Pets Best Insurance in their employee benefit programs. Affinity Groups may be an association group or a labor union group that provides various member benefits to the group. 2) and 3) This business has better-than-average loss experience and high retention rates. It also incurs lower marketing and acquisition costs due to its inclusion in a select menu of benefits endorsed by the insureds employer or member organization.</s><s>[INST]Generate another objection to this filing.[/INST]Our records indicate that the deemer date for this filing is May 02,2023. In order for us to complete our review, we request a waiver of the deemer. We ask that Independence American Insurance Company submits a SERFF response with the wording below to waive the deemer provisions: Regarding the above-referenced rate application, Independence American Insurance Company ("applicant") hereby waives all deemer provisions of California Insurance Code Section 1861.05, specifically, the 60-day deemer and the 180-day deemer. If the applicant wishes to reactivate the deemer provisions, the applicant will make its request in writing to the Department of Insurance Rate Filing Bureau, Oakland, California. Upon reactivation, the 60-day deemer will resume five days after the Department's receipt of the applicant's request to reactivate the deemer, on day 46, and the 180-day deemer will resume five days after the Department's receipt of the applicant's request to reactivate the deemer, on day 67.</s><s>[INST]Generate a response to this objection.[/INST]Regarding the above-referenced rate application, Independence American Insurance Company ("applicant") hereby waives all deemer provisions of California Insurance Code Section 1861.05, specifically, the 60-day deemer and the 180-day deemer. If the applicant wishes to reactivate the deemer provisions, the applicant will make its request in writing to the Department of Insurance Rate Filing Bureau, Oakland, California. Upon reactivation, the 60-day deemer will resume five days after the Department's receipt of the applicant's request to reactivate the deemer, on day 46, and the 180-day deemer will resume five days after the Department's receipt of the applicant's request to reactivate the deemer, on day 67.</s><s>[INST]Generate another objection to this filing.[/INST]Please provide a marked-up copy of the rate pages and the policy forms comparing them to what was approved for American Pet Insurance.</s><s>[INST]Generate a response to this objection.[/INST]Please see the marked up rate pages along with the marked up policy forms in Supporting Documentation.</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]Regrading exhibit 20: The company stated, "As existing Pets Best business will be retained under its current program, with no intent to transfer this filing does not result in a rate adjustment to any individual customer. " 1.) To confirm, American Pet is keeping all current insureds under this program and will no longer write business under this program. Which is why the company did not provide any dislocation data correct? 2.) To confirm once this transfer program is approved, only new business will be written, correct?</s><s>[INST]Generate a response to this objection.[/INST]1) Yes, this is correct. Insureds currently underwritten by APIC will remain with APIC and will not be subject to the proposed rate change or any dislocation. 2) Yes, this is correct.</s><s>[INST]Generate another objection to this filing.[/INST]Please provide a rating example comparing the current rates with the proposed 28.6% rate increase.</s><s>[INST]Generate a response to this objection.[/INST]Please see the attached CA Rating Example 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]Regarding exhibit 5: Of the 5pt options, please explain why the company chose 12pt to be the most actuarially sound selection.</s><s>[INST]Generate a response to this objection.[/INST]As this book of business has expanded rapidly, the 8-pt and 12-pt trends represent the current portfolio better than the longer-term averages. The 12-pt trend was selected over the 8-pt trend for the greater stability offered by the additional 4 quarters of data, and also aligns with our 12-point loss trend selection.</s><s>[INST]Generate another objection to this filing.[/INST]Understanding that the discounts proposed in the rate pages were previously approved for American Pets, the Department requires support. Discounts should be based on a loss relationship related to the risk. For each of the discounts listed below, please provide actuarial support and explain the relationship to loss. 1.) Strategic Partner Discount 2.) Multiple Pet Discount 3.) Web Link Partner 4.) Vet Staff Discount 5.) Employer and Affinity Groups <1,000 6.) Employer and Affinity Groups1,000 + Employees 7.) Pets Best Employees 8.) Pets Best Veterinary Examination Program CAplus SERFF Tracking #: IAIC-133555951 State Tracking #: 23-451 Company Tracking #: PB ME TOO (APIC) PRODUCT FILING-CA State: California Filing Company: Independence American Insurance Company TOI/Sub-TOI: 09.0 Inland Marine/09.0004 Pet Insurance Plans Product Name: PetsBest 2023 Transferred Product Filing Project Name/Number: PETSBEST/TRANSFERRED PRODUCT FILING-2023 INDIVIDUAL PDF Pipeline for SERFF Tracking Number IAIC-133555951 Generated 05/22/2023 12:47 AM</s><s>[INST]Generate a response to this objection.[/INST]Please see the included Discount Experience Exhibit showing loss ratios by Pets Best discount countrywide and for California. As the discount program is intended to be countrywide, most consideration has been given to the countrywide data, but CA info has been provided to demonstrate that the state-specific loss ratio relationships are similar. For the discounts that are fully credible countrywide (Strategic Partner, Employer and Affinity Groups <1,000, Employer and Affinity Groups 1,000 + Employees, Multiple Pet Discount, Military Discount), the indicated discount amount based on experience is greater than or equal to the currently approved APIC discounts, which we are filing to maintain. Although the Web-link Partner and Pets Best Employees discounts do not have full credibility even on a countrywide basis, the currently approved discounts are still less than or equal to the raw indicated amounts. However, the Vet Staff Discount and the Pets Best Veterinary Examination Program CAplus do not appear to be supported by loss experience. As a result, we are proposing to remove these discounts. Generally, this would result in a base rate offset to maintain overall rate level, however, the total premium to which these discounts apply in CA is so small that the potential offset is not material In 2022, only 286 out of 102K pets received the Vet Staff discount; only 11 pets received Pets Best Veterinary Examination Program CAplus. Clean and marked-up rate pages reflecting this change have been provided.</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 update exhibit 10 to include the following in excel with working formulas: EXPERIENCE CREDIBILITY 1.) Calculation of partial credibility for experience. 2.) Units (e.g., claim count, exposure etc.) used to calculate partial credibility. 3.) If claim count is used to calculate partial credibility, type of claim count (e.g., incurred) used to calculate partial credibility.) 4.) Calculation of the full credibility standard for experience. LOSS TREND CREDIBILITY 1.) Calculation of partial credibility for loss trend. 2.) Units (e.g., claim count, exposure etc.) used to calculate partial credibility. 3.) If claim count is used to calculate partial credibility, type of claim count (e.g., incurred) used to calculate partial credibility.) 4.) Calculation of the full credibility standard for loss trend.</s><s>[INST]Generate a response to this objection.[/INST]We have updated Exhibit 10 to include the partial credibility calculation for both experience credibility and loss trend credibility. Pets Best uses paid claims to calculate credibility.</s><s>[INST]Generate another objection to this filing.[/INST]1.) CW Premium NOT Subject to Prop 103 does not match between Rate Template 4.1 and our records for years 2019, 2020, and 2021. I am comparing with the NAIC statement for NAIC code 26581 (NAIC code 26581). 2019: Template 342,354,000 VS Our records 105,974,000 2020: Template 360,802,000 VS Our records 88,826,000 2021: Template 402,959,000 VS Our records 60,194,000</s><s>[INST]Generate a response to this objection.[/INST]What we have included as premium on page 4.1 is the premium for the entire Independence Holding Company insurer group, rather than just IAIC. IAIC did not have any executives as it was held by the Independence Holding Company during 2019 - 2021 and therefore we would have no salaries to include (NAIC Group Code 0450, which includes Independence Amer Ins Co 26581, Madison Natl Life Ins Co Inc. 65781, and Standard Security Life Ins Co Of NY 69078). This is consistent with how we have filled this sheet out in the past and is also consistent with our discussions with the Deputy Commissioner on how to properly fill out this form. Please note, IAIC is no longer a part of Independence Holding Company and as such, in the future when we include information for the 2022 year, it will represent IAIC only.</s><s>[INST]Generate another objection to this filing.[/INST]Total Advertising does not match between Rate Template 4.1 and our records for year 2021. I am comparing with the NAIC statement for NAIC code 26581 (NAIC code 26581). 2021: Template 1,000 VS Our records 2,000</s><s>[INST]Generate a response to this objection.[/INST]I apologize; please see the revised Rate Template which has been updated to reflect the total advertising amount of 2,000 as found in the Insurance Expense Exhibit Part 1 Line 4. As the most recent Rate Template reflects updated efficiency standards, the indicated change produced by the rate template has increased. We have not proposed any changes to the rates but have submitted an updated Application reflecting this updated indicated change.</s><s>[INST]Generate another objection to this filing.[/INST]1.) Please explain why data in the Paid DCCE triangle (Exhibit 7) of the Standard Exhibits Template is all zeroes for this coverage/form/program. 2.) Please explain why data in the Incurred DCCE triangle (Exhibit 7) of the Standard Exhibits Template is all zeroes for this coverage/form/program.</s><s>[INST]Generate a response to this objection.[/INST]1) The company has not incurred any DCCE for this program to date. As such, the Paid DCCE triangle is all zeroes. 2) The company has not incurred any DCCE for this program to date. As such, the Incurred DCCE triangle is all zeroes.</s><s>[INST]Generate another objection to this filing.[/INST]1.) The Incurred Loss development triangle is equal to the Paid Loss development triangle for this coverage/form/program in the Standard Exhibits Template. Incurred Loss should include case reserves, while Paid Loss should not. SERFF Tracking #: IAIC-133555951 State Tracking #: 23-451 Company Tracking #: PB ME TOO (APIC) PRODUCT FILING-CA State: California Filing Company: Independence American Insurance Company TOI/Sub-TOI: 09.0 Inland Marine/09.0004 Pet Insurance Plans Product Name: PetsBest 2023 Transferred Product Filing Project Name/Number: PETSBEST/TRANSFERRED PRODUCT FILING-2023 INDIVIDUAL PDF Pipeline for SERFF Tracking Number IAIC-133555951 Generated 05/22/2023 12:47 AM Please correct your data, or provide an explanation. 2.) The Incurred DCCE development triangle is equal to the Paid DCCE development triangle for this coverage/form/program in the Standard Exhibits Template, yet you indicated on '1.General' that track you DCCE on an incurred basis (which we take to mean you case reserve for DCCE). Incurred DCCE should include case reserves, while Paid DCCE should not. Please correct your data, or provide an explanation.</s><s>[INST]Generate a response to this objection.[/INST]1) As this line of business pays claims very quickly, we do not calculate and hold specific case reserves. We do not believe case specific reserve methods would materially improve the reserving process. For this reason, our calculation of paid and incurred loss development on exhibit 7 is the same. 2) As stated above, company has not incurred any DCCE for this program to date. This line of business pays claims very quickly and we do not calculate and hold specific case reserves.</s><s>[INST]Generate another objection to this filing.[/INST]The Paid Claim Counts + Closed With No Payment Claim Counts development triangle is equal to the Reported Claim Counts development triangle for this coverage/form/program in the Standard Exhibits Template. Paid Claims + Claims Closed With No Payment should theoretically include only open paid claims, closed paid claims, and claims closed without payment; Reported Claims, however, include the aforementioned claim types as well as open unpaid claims. Therefore, I expect Paid Claim Counts + Closed With No Payment Claim Counts to not be a 100% match with Reported Claim Counts. Please correct your data, or provide an explanation.</s><s>[INST]Generate a response to this objection.[/INST]We do not receive reported claims before they are paid. As a result, we do not have open claims to include in the development triangles, making the Paid Claim Counts + Closed With No Payment Claim Counts development triangle equal to the Reported Claim Counts development triangle.</s><s>[INST]Generate another objection to this filing.[/INST]Affidavit: Provide the Company Tracking Number not the SERFF Tracking Number. See footnote 1.</s><s>[INST]Generate a response to this objection.[/INST]I apologize; please see the updated Affidavit, now reflecting the Company Tracking Number.</s>
<s>[INST]<<SYS>>Review this pet insurance filing. Company: Liberty Insurance Underwriters Inc. Product: Pet Insurance State: California Date: 10/06/2022 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, and 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] Please revise and resubmit the Affidavit. 1. ONLY digital signatures with Adobe certificate-based signatures 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</s><s>[INST]Generate a response to this objection.[/INST]We updated affidavit as requested.</s><s>[INST]Generate another objection to this filing.[/INST]Please use the 6-27-2022 version of the Rate Application. The new version has been posted to the California Department of Insurance public website and SERFF.</s><s>[INST]Generate a response to this objection.[/INST]We updated Rate Application as requested.</s><s>[INST]Generate another objection to this filing.[/INST]A filing with multiple variances must include one Rate Template for each individual variance as well as the combined impact of all variances. Please submit the missing individual variance. See Page 16 of our Filing Instructions. 1. Rate Template VAR 7A</s><s>[INST]Generate a response to this objection.[/INST]We provided Rate Template for each individual variance.</s>
<s>[INST]<<SYS>>Review this pet insurance filing. Company: Lemonade Insurance Company Product: Pet Insurance State: California Date: 12/22/2021 Description: Filing Description: SERFF Tracking #: LEMO-133085983 State Tracking #: 22-47 Company Tracking #: LIC-PET-CA-2112 State: California Filing Company: Lemonade Insurance Company TOI/Sub-TOI: 09.0 Inland Marine/09.0004 Pet Insurance Plans Product Name: Pet Insurance Project Name/Number: Form/Rate/Rule Change/ PDF Pipeline for SERFF Tracking Number LEMO-133085983 Generated 07/13/2023 01:18 A <</SYS>> Generate an objection to this filing.[/INST] The Proposed Overall Rate Change that you have provided on pages 1 & 4 of the Rate Application (23%) is inconsistent with the Proposed Overall Rate Change (0%) on pages 1 & 2 of the Rate Template. Please verify and amend as appropriate. .</s><s>[INST]Generate a response to this objection.[/INST]With our initial submission we erroneously provided the incorrect Proposed Overall Rate Change of 23% on pages 1 & 4 of the Prior Approval Rate Application. The correct Proposed Overall Rate Change is 22.9%. We have corrected the Proposed Overall Rate Change on pages 1 & 4 of the Prior Approval Rate Application, and pages 1 & 2 of the Prior Approval Rate Template to reflect 22.9%. We apologize for any confusion. Please see the following updated documents: PriorAppRateAPL_Ed06-11-2021 - Lemonade v.2.pdf, PriorAppRateAPL_Ed06-11-2021 - Lemonade v.2.xlsm, PriorAppRateTl_Ed06-01-2021 - Lemonade v.2.xlsm & PriorAppRateTl_Ed06-01-2021 - Lemonade v.2.pdf. Also, we inadvertently provided an incorrect description in our Exhibit 7 pdf. This has been corrected in our updated response. We apologize for the error. Please see Exhibit 7 Loss and Defense and Cost Containment Expense Development Factors v.2.pdf.</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: Pet Health State: California Date: 05/03/2023 Description: Filing Description: The company is filing to update endorsement GPTM 406 1120 A, with the following below changes. The new version will be GPTM 406 0223 A. The Company is filing to remove, without prejudice, exclusionary wording regarding the treatment by a Veterinarian, immediate family member, member of the same household or business associate of the owner. The company recently filed to withdraw endorsement GPTM 601 0522 which contained similar exclusionary wording which was approved. To be consistent, we want to afford the same coverage under the wellness coverage form. The company would also like to make the following updates to the GPTM 406 form: Added line item to separate Canine Rabies & Feline Rabies as one set of vaccines and Canine Lyme & Feline FIP as a separate set of vaccines for a total of 4 sets of vaccines (4 for cats/4 for dogs) Language is added to clarify that all Wellness and Preventative Care Benefits must be performed for preventative reasons. In addition, if a claim is the result of an injury or illness or if a medical condition is revealed, the entire visit will be reviewed under the illness and injury section of the policy. Amended Treatment and Veterinarian definition to more adequately define specific to Wellness and Preventative Care Benefits We have attached in the supporting documentation a complete red-lined copy and a final clean copy of form GPTM 406 for your review with all changes outlined above. <</SYS>> Generate an objection to this filing.[/INST] As required, submit also clean copy of the current (previously approved) forms. See page 11 our filing instructions for additional information.</s><s>[INST]Generate a response to this objection.[/INST]Please see clean copy of form GPTM 406 1120 A.</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 ALL the required pages and exhibits shown on page 3 of the Applications filing checklist. If an exhibit is not applicable, explain the reason on the filing memorandum. 1. Affidavit 2. Exhibit 1 SERFF Tracking #: AXSS-G133613298 State Tracking #: 23-1383 Company Tracking #: FETCH-2023-03-0022-CA 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: 2023 FETCH Wellness Form Revision/FETCH-2023-03-0022 PDF Pipeline for SERFF Tracking Number AXSS-G133613298 Generated 07/17/2023 12:24 AM 3. Filing memorandum</s><s>[INST]Generate a response to this objection.[/INST]Please see required pages and exhibits attached.</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: Veterinary Pet Insurance Company Product: Percent of Invoice Plan A State: California Date: 07/11/2022 Description: Filing Description: Veterinary Pet Insurance Company (VPI) is submitting for your approval revisions to our existing rates and rules for our Percent of Invoice - Plan A (POIA). 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 restructuring our manual pages from our Veterinary Pet Insurance Program and are submitting the filing as a Percent of Invoice Plan A standalone manual and will be a standalone manual going forward. Please see the attached CA POIA Filing Memo in the Supporting Documentation tab under Manual Table for additional information. We are requesting that this filing apply to all new business and renewal policies written effective on or after August 11, 2023, or within 90 days of the date of approval. <</SYS>> Generate an objection to this filing.[/INST] Fill out the Affidavit completely. Provide the Application type and Group Name.</s><s>[INST]Generate a response to this objection.[/INST]I have updated the affidavit to include the Group Name in the file Affidavit_updated. Prior Approval Rate Application in the drop down was selected though. Hopefully you can see it on your side.</s><s>[INST]Generate another objection to this filing.[/INST]Fill out the Affidavit completely.</s><s>[INST]Generate a response to this objection.[/INST]The Affidavit has been updated to include my phone number.</s><s>[INST]Generate another objection to this filing.[/INST]The type of filing in SERFF (Rate/Rule) and on the application (Rate) is inconsistent. Please verify the correct type of filing. If SERFF is wrong, withdraw the filing and then refile with correct filing type. If the application is wrong, please submit a revised one. Also, submit page 10 of the Application. See page 16 of our prior approval filing instructions for more information.</s><s>[INST]Generate a response to this objection.[/INST]This should be a Rate/Rule filing so the app has been updated accordingly.</s>
<s>[INST]<<SYS>>Review this pet insurance filing. Company: AXIS Insurance Company Product: Pet Health State: California Date: 06/07/2023 Description: Filing Description: Under SERFF Tr Num: MRTN-132496576 and State Tr Num: 20-3323, an approved filing, the Company submitted a filing which included the form Pet Health Insurance Policy Terms and Conditions, GPTM 050 CA 0520 A. The Company is filing a revised Pet Health Insurance Policy Terms and Conditions, GPTM 050 CA 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 CA 0223 A and all other forms submitted with this filing, if applicable. <</SYS>> Generate an objection to this filing.[/INST] As required, submit also a clean copy of the current (previously approved) forms. See page 11 our filing instructions for additional information.</s><s>[INST]Generate a response to this objection.[/INST]Please see current approved form GPTM 050 CA 0520 A attached.</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 Individual Pet - Rates State: Connecticut Date: 09/13/2022 Description: Filing Description: This is a rate filing to accompany the corresponding form filing which has been submitted under SERFF ID# IAIC-133336151 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] Please provide the CT state tracking number of the United States Fire insurance Company filing that the company used to develop the base rates.</s><s>[INST]Generate a response to this objection.[/INST]The CT state tracking number of the United States Fire insurance Company filing that the company used to develop the base rates is CRUM-132530243.</s>
<s>[INST]<<SYS>>Review this pet insurance filing. Company: Accredited Surety and Casualty Company, Inc. Product: ManyPets Pet Insurance Program State: Connecticut Date: 01/19/2023 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] The company began writing in CT in 2021, therefore that filing should have clearly reflected the 21% veterinary costs you point to in your memorandum. You then go on to site an 11% trend U.S. News and world report but provide and the actuarial information is heavily skewed toward the over inflated trend in our opinion. We find this rate filing to be excessive. The department is not accepting inflationary adjustments over 8% without support based on the insurers experience in CT and based on the information provided we cannot accept anything over 14%. Please modify the filing based on this adjustment or the filing should be withdrawn.</s><s>[INST]Generate a response to this objection.[/INST]The Countrywide and Connecticut rate indications were revised to reflect a loss trend of 8%. Also, the proposed base rate was revised to achieve an Overall % Rate Impact of 14.0%, which is supported by the revised Overall % Indicated Change. The revised CT state exception page, along with the revised supporting exhibits, are submitted with this response. We have already made the updates to the rate schedule via most submission update.</s><s>[INST]Generate another objection to this filing.[/INST]Basing an increase based solely on a publication is not acceptable. The company will need to provide actuarial supported support! Please withdraw this filing and resubmit when there is actuarial credible data supporting the increase request. If the company would like to file an inflationary adjustment based on inflation the Department would allow an 8% maximum increase.</s><s>[INST]Generate a response to this objection.[/INST]My apologies - we have included our indications in our reply this afternoon.</s>
<s>[INST]<<SYS>>Review this pet insurance filing. Company: American Pet Insurance Company Product: Trupanion State: Connecticut Date: 02/24/2023 Description: Filing Description: American Pet Insurance Company (“APIC”) submits this form filing to revise forms from our recently approved filing with SERRF Tr Num: APII-133352476. The non-substantive changes for all documents are outlined in the explanatory memorandum on the Supporting Documentation tab. <</SYS>> Generate an objection to this filing.[/INST] The Department does not understand this side-by-side comparison. Where are the redlined changes? What do the red triangles mean? Please submit an actual marked-up copy for the Department to review.</s><s>[INST]Generate a response to this objection.[/INST]We apologize for the confusion, this is the first time we used the new document comparison tool provided by SERFF to create redlines. New redlines for the Declaration pages and Policy have been added to the Supporting Documentation tab in SERFF. When viewing the PDF we recommend changing your view to "two-page" and you can see the changes side-by-side. The right side is the New document. An amendment has also been submitted for the policy to correct an error in the Canadian member contact information. The new redlines correspond to this version of the policy. Thank you!</s>
<s>[INST]<<SYS>>Review this pet insurance filing. Company: Independence American Insurance Company Product: 2023 Individual Pet - Forms State: Georgia Date: 09/12/2022 Description: Filing Description: RE: Independence American Insurance Company NAIC # 26581 Individual Pet Insurance forms Form Number and Form Name IAIC-IND-2023-A-POL-XX - Accident Only Policy IAIC-IND-2023-AI-POL-XX - Accident and Illness Policy IAIC-IND-2023-APP-XX - Application 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-133336261. 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 SERFF Tracking #: IAIC-133336339 State Tracking #: Company Tracking #: 2023 INDIVIDUAL PET FORMS - GA State: Georgia Filing Company: Independence American Insurance Company TOI/Sub-TOI: 09.0 Inland Marine/09.0004 Pet Insurance Plans Product Name: 2023 Individual Pet - Forms Project Name/Number: / PDF Pipeline for SERFF Tracking Number IAIC-133336339 Generated 10/20/2022 02:21 A <</SYS>> Generate an objection to this filing.[/INST] Pursuant to OCGA 33 24 9, the department. only reviews and approves forms that are part of the policy that is delivered to the insured, please WD this item form the Forms Schedule tab because it does not form part of the policy.</s><s>[INST]Generate a response to this objection.[/INST]Your comments in this regard identified a clerical filing error. We did not intend to file an application to attach to or become part of the policy. We are hereby withdrawing our application from this filing package.</s><s>[INST]Generate another objection to this filing.[/INST]Claims involving fraud or misrepresentation indicates cancellation of policy will effective the date such fraud or misrepresentation is determined. Policy can only be cancelled per notice requirements of OCGA 33-24-47, i.e. 10 days notice for non-payment of premium or policy has been in effect less than 60 days, 45 days for all other reasons.</s><s>[INST]Generate a response to this objection.[/INST]Our review of the citation provided GA ST § 33-24-47 reflects that pursuant to subsection (a), this Code section shall not apply topersonal property and casualty insurance policies. As our pet insurance product is a personal property policy, it is our position that this statute does not apply to this product. That being said, in light of our objection, we have reviewed Georgia law and have made revisions to our Claims Involving Misrepresentation of Fraud, Termination, and Fraud and Misrepresentation of Material Fact provisions in order to align more closely with the applicable language and time frames under GA ST §§ 33-24-44 and 33-24-46.</s><s>[INST]Generate another objection to this filing.[/INST]Fraud, Misrepresentation of Material Fact: Please amend to replace "void " wording because pursuant to OCGA 33 24 7, coverage is prevented and not rescinded as though it never existed. Furthermore, the coverage and policy did take place up, so if the insurer wants to get off the contract or some of it's coverages, then the insurer is required to be in compliance with OCGA 33 24 47 whereby 45 days notice of cancellation is sent to the insured "prior" to the termination date.</s><s>[INST]Generate a response to this objection.[/INST]Our review of the citation provided GA ST § 33-24-47 reflects that pursuant to subsection (a), this Code section shall not apply topersonal property and casualty insurance policies. As our pet insurance product is a personal property policy, it is our position that this statute does not apply to this product. That being said, in light of our objection, we have reviewed Georgia law and have made revisions to our Claims Involving Misrepresentation of Fraud, Termination, and Fraud and Misrepresentation of Material Fact provisions in order to align more closely with the applicable language and time frames under GA ST §§ 33-24-44 and 33-24-46.</s><s>[INST]Generate another objection to this filing.[/INST]Other Insurance provision indicates coverage is excess of all other valid and collectible insurance. This is a primary rather than an excess policy, Amend Other Insurance to coordinate and share pro rata with all other valid and collectible insurance.</s><s>[INST]Generate a response to this objection.[/INST]Thank you for your comment. Despite our best efforts, we have been unable to locate a requirement with force of law that would prohibit a property insurance carrier from including an apportionment clause in a policy that would serve to make its coverage excess or secondary in situations in which an insured has taken out concurrent insurance policies covering the same interest and risks. We have also been unable to locate a requirement with force of law that would require a property insurance carrier to provide a pro-rata share of benefits in situations of other/double insurance coverage. As such, we request that you direct us to a relevant citation so that we may ensure and confirm full compliance and revise our forms accordingly.</s><s>[INST]Generate another objection to this filing.[/INST]Claims involving misrepresentation or fraud, cancellation must be in accord with OCGA 33-24-47.</s><s>[INST]Generate a response to this objection.[/INST]Our review of the citation provided GA ST § 33-24-47 reflects that pursuant to subsection (a), this Code section shall not apply topersonal property and casualty insurance policies. As our pet insurance product is a personal property policy, it is our position that this statute does not apply to this product. That being said, in light of our objection, we have reviewed Georgia law and have made revisions to our Claims Involving Misrepresentation of Fraud, Termination, and Fraud and Misrepresentation of Material Fact provisions in order to align more closely with the applicable language and time frames under GA ST §§ 33-24-44 and 33-24-46.</s><s>[INST]Generate another objection to this filing.[/INST]Non-renewal notice and any termination notice by insurer must comply with OCGA 33-24-47.</s><s>[INST]Generate a response to this objection.[/INST]Our review of the citation provided GA ST § 33-24-47 reflects that pursuant to subsection (a), this Code section shall not apply topersonal property and casualty insurance policies. As our pet insurance product is a personal property policy, it is our position that this statute does not apply to this product. That being said, in light of our objection, we have reviewed Georgia law and have made revisions to our Claims Involving Misrepresentation of Fraud, Termination, and Fraud and Misrepresentation of Material Fact provisions in order to align more closely with the applicable language and time frames under GA ST §§ 33-24-44 and 33-24-46. Please note that we did not revise our non-renewal provision as it currently allows for a minimum advance notice of 30 days, which is in compliance with Georgia law. Although the notification is bracketed for variability, it is bracketed only to the extent that we would provide more days of advance notice than that required in under applicable Georgia law.</s><s>[INST]Generate another objection to this filing.[/INST]Fraud, Misrepresentation of a material fact: Amend to replace "void " wording because pursuant to OCGA 33 24 7, coverage is prevented and not rescinded as though it never existed. Furthermore, the coverage and policy did take place up, so if the SERFF Tracking #: IAIC-133336339 State Tracking #: Company Tracking #: 2023 INDIVIDUAL PET FORMS - GA State: Georgia Filing Company: Independence American Insurance Company TOI/Sub-TOI: 09.0 Inland Marine/09.0004 Pet Insurance Plans Product Name: 2023 Individual Pet - Forms Project Name/Number: / PDF Pipeline for SERFF Tracking Number IAIC-133336339 Generated 10/20/2022 02:21 AM insurer wants to get off the contract or some of it's coverages, then the insurer is required to be in compliance with OCGA 33 24 47 whereby 45 days notice of cancellation is sent to the insured "prior" to the termination date.</s><s>[INST]Generate a response to this objection.[/INST]Our review of the citation provided GA ST § 33-24-47 reflects that pursuant to subsection (a), this Code section shall not apply topersonal property and casualty insurance policies. As our pet insurance product is a personal property policy, it is our position that this statute does not apply to this product. That being said, in light of our objection, we have reviewed Georgia law and have made revisions to our Claims Involving Misrepresentation of Fraud, Termination, and Fraud and Misrepresentation of Material Fact provisions in order to align more closely with the applicable language and time frames under GA ST §§ 33-24-44 and 33-24-46.</s><s>[INST]Generate another objection to this filing.[/INST]Other Insurance provision indicates coverage is excess. This is a primary policy and should share pro rate with any other valid and collectible insurance.</s><s>[INST]Generate a response to this objection.[/INST]Thank you for your comment. Despite our best efforts, we have been unable to locate a requirement with force of law that would prohibit a property insurance carrier from including an apportionment clause in a policy that would serve to make its coverage excess or secondary in situations in which an insured has taken out concurrent insurance policies covering the same interest and risks. We have also been unable to locate a requirement with force of law that would require a property insurance carrier to provide a pro-rata share of benefits in situations of other/double insurance coverage. As such, we request that you direct us to a relevant citation so that we may ensure and confirm full compliance and revise our forms accordingly.</s>
<s>[INST]<<SYS>>Review this pet insurance filing. Company: Liberty Insurance Underwriters Inc. Product: Pet Insurance State: Georgia 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] Remove all references to arbitration which is not allowed in Georgia in an insurance contract. See OCGA 9-9-2.</s><s>[INST]Generate a response to this objection.[/INST]A Georgia specific comparison is provided.</s>
<s>[INST]<<SYS>>Review this pet insurance filing. Company: National Casualty Company Product: Pet Insurance State: Georgia Date: 10/26/2022 Description: Filing Description: National Casualty Company (NCC) is submitting for your approval revisions to our coverage forms for our VBW-I Plan. We are updating our coverage forms to provide clarity of our policy definitions, exclusions and policy terms. The proposed updates do not reduce coverage. 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] Regarding the Other Insurance provision which indicates coverage is excess, such provision when contained by 2 policies issued to the same risk have been deemed mutually repugnant by the courts. Remedy by Georgia court cases, i.e. National Casualty Co., V. Ga. School Boards Risk Mgmt Fund 2018, and others, is to have policies with conflicting excess other insurance provisions to share pro rata. In other words, unless a policy is specifically written to be excess and clearly stated as such in the insuring agreement, to avoid conflict, delay in claim settlement, costly litigation, etc., policies written as primary will and should share pro rata if there is other valid and collectible insurance in effect. This is a department guideline for insurance policies that are not specifically issued as excess or umbrella type policies. Failure to modify the other insurance provision to provide pro rata will result in disapproval of this filing.</s><s>[INST]Generate a response to this objection.[/INST]Please refer to attached responses.</s><s>[INST]Generate another objection to this filing.[/INST]Fraud; Amend to replace "void " wording pursuant to OCGA 33 24 7, coverage is prevented and not rescinded as though it never existed. Furthermore, the coverage and policy did take place up, so if the insurer wants to get off the contract, the insurer is required to be in compliance with OCGA 33 24 47 whereby 45 days notice of cancellation is sent to the insured "prior" to the termination date. Regarding the Other Insurance provision which indicates coverage is excess, such provision when contained by 2 policies issued to the same risk have been deemed mutually repugnant by the courts. Remedy by Georgia court cases, i.e. National Casualty Co., V. Ga. School Boards Risk Mgmt Fund 2018, and others, is to have policies with conflicting excess other insurance provisions to share pro rata. In other words, unless a policy is specifically written to be excess and clearly stated as such in the insuring agreement, to avoid conflict, delay in claim settlement, costly litigation, etc., policies written as primary will and should share pro rata if there is other valid and collectible insurance in effect. This is a department guideline for insurance policies that are not specifically issued as excess or umbrella type policies. Failure to modify the other insurance provision to provide pro rata will result in disapproval of this filing.</s><s>[INST]Generate a response to this objection.[/INST]Please refer to attached responses.</s>
<s>[INST]<<SYS>>Review this pet insurance filing. Company: Cimarron Insurance Company, Inc. Product: Pet Insurance Program State: Georgia Date: 11/29/2022 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 (GA). <</SYS>> Generate an objection to this filing.[/INST] (11) The department will acknowledge a 7% profit factor, not 10.2%</s><s>[INST]Generate a response to this objection.[/INST]The profit provision has been revised to 7.0%. Please see the revised exhibit 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: Independence American Insurance Company Product: 2023 VERSION 4 State: Georgia Date: 04/11/2023 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] 1.Regarding page 1; Please amend to remove rescind wording because per OCGA 33 24 7, coverage is prevented and not rescinded as though it never existed. Furthermore, the coverage and policy did take place, so if the insurer wants to cancel/terminate the contract, then the insurer is required to be in compliance with OCGA 33 24 47 whereby 45 days notice of cancellation is sent to the insured "prior" to the termination date Please amend to such as; The policy is governed by the laws of the state in which it was delivered. If you intentionally misrepresent or conceal any material fact, we may deny any related claim, and cancel the policy. The policy will lapse if you do not pay your premium when due. You are financially responsible to your veterinarian for services provided. This policy reimburses you for covered expenses as described. 2.Regarding page 5 and WHAT IS NOT COVERED; Please amend to remove We will not pay for expenses related to any Illness. Because the on page 4 of the policy under [Illness Benefits, there is wording that says the insurer will pay expenses for illness. 3.Regarding page 8, Excess Insurance Limitation Since the policy is not written as excess, then please amend to share the loss proportionately with similar type of insurance. Such as; Excess Insurance Limitation If at the time of treatment, there is other valid and collectible insurance in place, that is also similar to this insurance, then we shall only be liable for a proportionate share of the loss.</s><s>[INST]Generate a response to this objection.[/INST]1) The Georgia Amendatory Endorsement has been updated to remove the word rescind from the Insuring Agreement. As for the 45 days notice, per OCGA 33-24- 47(a): This Code section shall not apply to personal automobile or personal property and casualty insurance policies. 2) These sections are part of variable text fields and will be appropriately included. The inclusion of each will be determined by the consumer choice of Accident Only or Accident/Illness coverage. 3) The Excess Insurance Limitation has already been amended via the Georgia Amendatory Endorsement.</s><s>[INST]Generate another objection to this filing.[/INST]1. At whos option is this exclusion attached to the policy 2. How much of a credit does the insured get on their premium if this is attached?</s><s>[INST]Generate a response to this objection.[/INST]1) The exclusion module may be utilized to modify coverage based on the program design determined by the company. While previously approved, this endorsement has never been utilized and is not attached to any existing policies. 2) Please see the Rate/Rule Manual Table 2.7.1 in companion filing IAIC-133629399 for discount factors.</s><s>[INST]Generate another objection to this filing.[/INST]Since this endorsement amends the policy to have an exclusion, please amend the title to such as; Exclusion-Pre Existing Knee and Ligament Limitation Or SERFF Tracking #: IAIC-133629369 State Tracking #: Company Tracking #: 2023 VERSION 4 - GA State: Georgia Filing Company: Independence American Insurance Company TOI/Sub-TOI: 09.0 Inland Marine/09.0004 Pet Insurance Plans Product Name: 2023 VERSION 4 Project Name/Number: IAIC/2023 IAIC RATE FORM VERSION 4 PDF Pipeline for SERFF Tracking Number IAIC-133629369 Generated 06/01/2023 01:46 AM Limitation- Preexisting Knee and Ligament Because per OCGA(33-24-10(3), the GA policyholder has the right to non-misleading titles.</s><s>[INST]Generate a response to this objection.[/INST]This Amendatory Endorsement is actually an expansion of coverage. The Cured Condition Eligibility is revised and expanded to allow pre-existing conditions after a certain period, and the Pre-Existing exclusion (letter n.) is deleted entirely. This endorsement has no associated premium and is also only applicable to pets initially enrolled in the version prior to the 2018 revision to maintain existing benefits.</s>
<s>[INST]<<SYS>>Review this pet insurance filing. Company: American Pet Insurance Company Product: Pets Best Inc. Pet Health Insurance State: Georgia Date: 03/31/2023 Description: Filing Description: American Pet Insurance Company is filing to propose the following changes: Base Rates: Revising based on experience <</SYS>> Generate an objection to this filing.[/INST] Please provide the required histograms that reflect PH impact in both $ and %; One histograms that are uncapped,- should illustrate the policy holder impact by percentage change. The second histogram should illustrate the distribution of the rate level change by the dollar amount change on the policyholders.</s><s>[INST]Generate a response to this objection.[/INST]Please see attached for histograms for both capped and uncapped Policyholder impact in both dollar ($) and percentage (%) for ease of comparison. Thank you.</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: Pets Best Inc. Pet Health Insurance State: Georgia Date: 03/31/2023 Description: Filing Description: American Pet Insurance Company is filing to propose the following changes: Base Rates: Revising based on experience <</SYS>> Generate an objection to this filing.[/INST] Please provide the required histograms that reflect PH impact in both $ and %; One histograms that are uncapped,- should illustrate the policy holder impact by percentage change. The second histogram should illustrate the distribution of the rate level change by the dollar amount change on the policyholders.</s><s>[INST]Generate a response to this objection.[/INST]Please see attached for histograms for both capped and uncapped Policyholder impact in both dollar ($) and percentage (%) for ease of comparison. Thank you.</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: Pet Health State: Georgia Date: 04/12/2023 Description: Filing Description: Under SERFF Tr Num: AXSS-G132998246, 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 and a revised state amendatory, GPTM 100-GA 0223. 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] Since the policy is not written as excess, then please amend to share the loss proportionately with similar type of insurance</s><s>[INST]Generate a response to this objection.[/INST]The company has further revised its Georgia Amendatory Endorsement to address the Department's concerns.</s>
<s>[INST]<<SYS>>Review this pet insurance filing. Company: Trisura Insurance Company Product: Pet Health Insurance State: Georgia Date: 05/25/2023 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 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] Hello, since this is a new program where is this data coming from?</s><s>[INST]Generate a response to this objection.[/INST]The information used for this filing comes from Clear Blue filing SERFF MRTN-131973964. Please note Clear Blue is nonrenewing their accounts and they will be written with Norse Specialty Services, Inc.</s><s>[INST]Generate another objection to this filing.[/INST]Please provide the Clear Blue SERFF tracking number for which these rates are based. In the SD tab, per the I. Data and Calculations-New Programs, Introduction of Rates or Rating Variables, New Coverages, etc tab, this what is required when new program; 1. Competitive market study including at least 3 competitors. The study should include the names of the competitors and comments on the appropriateness of the selected rates. 2. The logic, facts, and calculations utilized if the rates are based upon actuarial or underwriting judgment. 3. A thorough actuarial analysis if sufficient data exist to develop credible charges. Attach this exhibit to the Supporting Documentation tab.</s><s>[INST]Generate a response to this objection.[/INST]MRTN-131973964</s>
<s>[INST]<<SYS>>Review this pet insurance filing. Company: Independence American Insurance Company Product: Figo NMB Rider State: Hawaii Date: 03/29/2022 Description: Filing Description: This filing is to submit an updated Non-Medical Benefits Rider for your review and approval. This Rider will be used with the previously approved pet insurance policy filed under IADC-132357221 approved on December 21, 2020. This Rider will be issued to all new business and existing policies at renewal. A redlined version has been added to Supporting Documentation to show the changes. This updated form does not impact currently approved rates. This filing is not being done for any other purpose. To the best of our knowledge, this filing is complete and intended to comply with the insurance laws of your jurisdiction. If you have any questions, or need additional information, please contact me. Sincerely, Diane Marlowe Sr Forms Development and Compliance Specialist <</SYS>> Generate an objection to this filing.[/INST] Please demonstrate compliance with Hawaii Revised Statutes §431:14-105 by advising: a) If the coverage being altered by the endorsements impact your currently approved rates. If it does, please provide an analysis of this impact. If the limits being listed in the endorsement form were not previously listed in the Dec page, please provide the analysis of the limits impact. b) If there are any specific rates or premium associated with these endorsements. If so, please provide the manual pages that include the specific rates or premium charges.</s><s>[INST]Generate a response to this objection.[/INST]The changes to the optional rider do not impact currently approved rates which were filed and approved under IADC-133061389. The Dec page will refer the consumer to the rider so the consumer can read the various benefits of this rider and see the different dollar amounts for each benefit. I have placed the 2 pertinent pages from the previously approved rate sheets in Supporting Documentation for "Rate Pages for Rider"</s>
<s>[INST]<<SYS>>Review this pet insurance filing. Company: American Pet Insurance Company Product: Pets Best Inc. Pet Health Insurance State: Hawaii Date: 07/28/2022 Description: Filing Description: American Pet Insurance Company is respectfully submitting an update to its current Pets Best Pet Health Insurance program. Details of the changes are outlined in the Actuarial Memorandum. - Base Rates: Revising based on experience. <</SYS>> Generate an objection to this filing.[/INST] To complete this filing, please submit a Post Submission Update and provide updated effective dates, backdating is not permitted.</s><s>[INST]Generate a response to this objection.[/INST]A Post Submission Update has been submitted with new effective dates. Thank you.</s><s>[INST]Generate another objection to this filing.[/INST]Thank you for your response 1 dated 9.30.22; however, we are still unable to locate your Return on Equity calculation. It is noted that company believes it has already provided the Return on Equity calculation and out put in Exhibit 8. In you response, please specifically identity what specific page and line item you believe the calculation is on. The following required exhibit is still outstanding.. 1) Please provide a Projected Return on Equity calculation that provides all income and outflow, and includes supporting data.</s><s>[INST]Generate a response to this objection.[/INST]Please see "Exhibit 9" attached in 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]Thank you for your response 2 dated 8.23.22 and the development of your profit provision. The following required exhibit was not provided. 1) Please provide a Projected Return on Equity calculation that provides all income and outflow, and includes supporting data.</s><s>[INST]Generate a response to this objection.[/INST]Thank you for the opportunity to respond. We believe this was addressed in Exhibit 8 and if it was not, we would like to request a phone call to better understand the exhibit the Department would like submitted. Thank you for your time and continued review.</s><s>[INST]Generate another objection to this filing.[/INST]Exhibit 2 and other exhibits estimates an earned premium of approximately $700k earned premium for the year end date of 12.31.21. The Company Rate Information section under the Rate/Rule Schedule tab of SERFF list a written premium of approximately $1.2M. This difference in premium is larger that what can easily be assumed as the timing difference between earned and written premium. Please provide your explanation for the large difference. If premium dollars were removed or reduced in any of the exhibits used in your rate support, please explain your reasons.</s><s>[INST]Generate a response to this objection.[/INST]The monthly earned premium for the policyholders for month end 3/31/2022 was ~$85K, projected out over 12 months would be just over $1.02M, closer to the $1.17M in SERFF.</s>
<s>[INST]<<SYS>>Review this pet insurance filing. Company: Independence American Insurance Company Product: PetsBest 01/2023 Rates State: Hawaii 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 6.9%. <</SYS>> Generate an objection to this filing.[/INST] 1) Please revise your actuarial memo to explain or speak to the the specific factor changes for the various coverage limits and coverage plans, provide supporting exhibits for your selections.</s><s>[INST]Generate a response to this objection.[/INST]Please see our newly attached actuarial memo. Page 2 of the previously submitted filed Hawaii - Exhibit - Experience 20220923.pdf contains support for the proposed changes to plan factors.</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: Liberty Insurance Underwriters Inc. Product: Pet Insurance State: Hawaii Date: 11/14/2022 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, and 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] Please remove the following rule: Rule II.A Base Rates are increased by an annual loss trend of 5.0% for every year after 2023. Please refile for rate change as needed.in the future.</s><s>[INST]Generate a response to this objection.[/INST]As per the request, we removed Rule II.A from Hawaii Exception Page.</s>
<s>[INST]<<SYS>>Review this pet insurance filing. Company: United States Fire Insurance Company Product: PET - V4.5 State: Hawaii Date: 11/16/2022 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 +7.7%. 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 and form; this form was originally approved under CRUM-131553265 and withdrawn in CRUM-132957574. There are no changes to the originally approved form aside from edition date. Removal of transition rule. <</SYS>> Generate an objection to this filing.[/INST] Please address the following: 1) Please specify your current territory factor and provide the statistical justification for the change. 2) Confirm the .608 discount factor is associated with the proposed exclusion. We could not locate this factor in your rating plan. Please explain or amend your filing accordingly.</s><s>[INST]Generate a response to this objection.[/INST]1) Territory factors do not exist in the current rating structure, but the implied territory factor in Hawaii is 1.0 since all zip codes are assigned to the same territory. No change to the existing territory definitions are being proposed, so the proposed territory factor will remain 1.0. 2) Please see Table 2.7.5 in the rating manual for the referenced discount factor.</s><s>[INST]Generate another objection to this filing.[/INST]Per Exhibit 3, please address the following: 1) Disclose the Partners A, B and C. 2) Clarify how the selected changes were determined.</s><s>[INST]Generate a response to this objection.[/INST]1) Partners A, B, and C are Petco, Pumpkin, and Spot, respectively. 2) The selected overall rate changes were determined with consideration given to the credibility of each channel. For example, the full indication for Direct was selected as it is the most credible book. In addition to having very little experience, the poor retention of Partner A has resulted in an artificially low loss ratio. As such, we felt that a selection close to current rates was appropriate for a slight rate reduction of -1.53%. Selections for Partners B and C were then made between current and indicated to achieve the same overall rate change as indicated.</s>
<s>[INST]<<SYS>>Review this pet insurance filing. Company: Independence American Insurance Company Product: 2023 Individual Pet State: Hawaii Date: 09/12/2022 Description: Filing Description: SERFF Tracking #: IAIC-133331841 State Tracking #: 263897 Company Tracking #: 2023 INDIVIDUAL PET - HI State: Hawaii Filing Company: Independence American Insurance Company TOI/Sub-TOI: 09.0 Inland Marine/09.0004 Pet Insurance Plans Product Name: 2023 Individual Pet Project Name/Number: / PDF Pipeline for SERFF Tracking Number IAIC-133331841 Generated 12/16/2022 01:07 A <</SYS>> Generate an objection to this filing.[/INST] Thank you identifying filings in your response dated 11.17.22 we will address those outside of this filing. Regarding your response dated 10.4.22: In general, admitted insurance companies are not permitted to use rates or factors that that have not been approved for use in Hawaii by the Hawaii Insurance Division (HID). Companies offering discounts for various classifications (groups) within their manual need to specifically list the rate or factor to be applied to the specific classification to demonstrate that the rates and rules will not be used in an unfairly discriminatory way. Proposed rate and factors should be accompanied by supporting exhibits or justification clearly explaining the development or selection of the rate or factor. Outstanding Objection: Based on your response dated 9.27.22, please remove the rating classification for the below listed groups. - Employer Group - Large Employer Group - Association Group - Large Association Group - Affinity Group - Large Affinity Group - Strategic Partner - Large Strategic Partner When the company is ready to add and name the specific group(s), it will permitted to submit the changes in a new filing. At that time supporting documents for the selected factors may be required.</s><s>[INST]Generate a response to this objection.[/INST]We received an updated listed for groups eligible for the discounts from Spot Pet Insurance Services LLC, who will be marketing the product. The manual has been revised accordingly.</s><s>[INST]Generate another objection to this filing.[/INST]Regarding your response dated 10.4.22: In general, admitted insurance companies are not permitted to use rates or factors that that have not been approved for use in Hawaii by the Hawaii Insurance Division (HID). Companies offering discounts for various classifications (groups) within their manual need to specifically list the rate or factor to be applied to the specific classification to demonstrate that the rates and rules will not be used in an unfairly discriminatory way. Proposed rate and factors should be accompanied by supporting exhibits or justification clearly explaining the development or selection of the rate or factor. Outstanding Objection: Based on your response dated 9.27.22, please remove the rating classification for the below listed groups. - Employer Group - Large Employer Group - Association Group - Large Association Group - Affinity Group - Large Affinity Group - Strategic Partner - Large Strategic Partner When the company is ready to add and name the specific group(s), it will permitted to submit the changes in a new filing. At that time supporting documents for the selected factors may be required.</s><s>[INST]Generate a response to this objection.[/INST]Based on the response from the department, we contend that our discount definitions found on pages 32 34 of the rate manual, do specifically list the factors to be applied to each classification and the rules that determine the eligibility for such discounts. In our review of recently approved pet insurance filings in the state, we have failed to find any rate manuals that specifically list the names of the groups. Below is the list of some filings by SERFF number and effective date. HI SERFF# Approval DateDiscount Types Included Group Names In Manual? APII-13343788211/16/2022Employee Benefit No STNA-1331987824/1/2022 Affinity Group, Corporate Group, & Strategic Partners No PHYS-1331831673/29/2022Employer, Strategic Partner & Affinity Group No As additional support for our proposed discounts we offer that the 10% discounts for a similar program were approved in the US Fire filing with SERFF# CRUM-132957574 for the following: Employer/Union Discount Association Group Discount Affinity Group Discount Strategic Partner Discount The 15% discount for Large Employer/Large Union Group, Large Association Group, Large Affinity Group, and Large Strategic Partner is based on the 10% discount along with an additional reduction in commission. The reduction of the commission results in loss ratio of 62.47% in comparison to the standard loss ratio of 59.0%. This difference in loss ratio compared to all other policies generates the additional 5% discount for groups meeting the qualifications for this higher discount, as 59.0% / 62.47% = 0.944. </s><s>[INST]Generate another objection to this filing.[/INST]Based on your response dated 9.27.22, please remove the rating classification for the below listed groups. - Employer Group - Large Employer Group - Association Group - Large Association Group - Affinity Group - Large Affinity Group - Strategic Partner - Large Strategic Partner When the company is ready to add and name the specific group(s), it will permitted to submit the changes in a new filing. At that time supporting documents for the selected factors may be required.</s><s>[INST]Generate a response to this objection.[/INST]We request clarification on whether we can offer a discount to a group when the discount has not been filed or available for use. This does not seem like a tenable position for us given that we cannot provide a group with the rates until we file the rates. Respectfully, we noted that Hawaii Insurance Division has approved similar language in rate filings for other carriers (see examples from Axis under SERFF number AXSS-G133152975, Zurich under SERFF number ZURC-131910511, and Markel under SERFF number MRKA-131609429). Is the pre-filing of the groups prior to the rates being deemed complete and on file a new requirement? Thank you for your assistance in helping us understand this requirement.</s><s>[INST]Generate another objection to this filing.[/INST]Please revise your manual to specifically list the names of the groups that qualify for a discount: - Employer Group - Large Employer Group - Association Group - Large Association Group - Affinity Group - Large Affinity Group - Strategic Partner - Large Strategic Partner</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]<<SYS>>Review this pet insurance filing. Company: Independence American Insurance Company Product: Pet First 04 2023 Rates State: Hawaii Date: 11/29/2022 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 Pet First Base rates are updated for trend and 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] Rate Level Indication Hawaii Experience: 1) Provide an exhibit for column J, confirm what data this is based on (ie company countrywide data, industry data, Hawaii industry data etc.)</s><s>[INST]Generate a response to this objection.[/INST]The Manual Change (column J) is based on the companys nationwide trend rate for this program and is used as the complement of credibility. The trend rate is applied for the time period between the effective date of the last rate filing to the proposed effective date, which for this filing is 12 months. Please see the attached Hawaii - Exhibit - Trend Development - 20221123.pdf for support of the selected non-wellness trend rate of 11.0% and the wellness trend rate of 0.0%.</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: Hawaii Date: 12/29/2022 Description: Filing Description: This filing is to amend the previous filing USAI-133463398. An error was realized in the filed zip codes. No other changes to the manual or rates are being requested. <</SYS>> Generate an objection to this filing.[/INST] Based on your representations, the Hawaii Insurance Division is in a position to approve this submission. Typically, zip-code based rating is prohibited in our state. However, since the entire state is essentially one classification, this provision was allowed. To conclude our review, please acknowledge your understanding that if you differentiate rating by zip codes (967 and 968 different factors) then this provision should be removed. In this regard, the Hawaii Insurance Division only permits differentiation by County for this product type.</s><s>[INST]Generate a response to this objection.[/INST]The company acknowledges that rating differentiation by zip code is not permissible in the state of Hawaii.</s>
<s>[INST]<<SYS>>Review this pet insurance filing. Company: WESTCHESTER FIRE INSURANCE COMPANY Product: 23-PIM-2021957 State: Hawaii 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 16.0% 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 Hawaii 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% on an uncapped to uncapped basis. 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 5/15/2023. <</SYS>> Generate an objection to this filing.[/INST] The filing fees are incorrect. Please amend accordingly.</s><s>[INST]Generate a response to this objection.[/INST]Additional fees have been sent.</s><s>[INST]Generate another objection to this filing.[/INST]In the Rate/Rule Schedule tab, you represent an indicated 16% rate change but select 3%. This also seems supported by your Actuarial Memorandum language. Exhibit: State Indication illustrates the development of the 16% indication. To confirm your representations, please revise Exhibit: State Indication to include your selected rate change percentage. If this selection differs from 3%, please further explain.</s><s>[INST]Generate a response to this objection.[/INST]Please see revised.</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: Hawaii Date: 01/19/2023 Description: Filing Description: Overall Rate Impact: +8.0% Proposed Effective Date: 4/1/2023 for new business and renewals Base rates are being revised based on experience. <</SYS>> Generate an objection to this filing.[/INST] Exhibit 6E Item M list a Profit provision of 5% and cites a table that does not appear to be provided for its development. 1) Please provide a Projected Return on Equity calculation exhibit that shows the development of your profit provision, ensure that it provides all income and outflow, and includes supporting data. If the company believes that it has already provided an ROE exhibit, please cite the exhibit and line item.</s><s>[INST]Generate a response to this objection.[/INST]Please see "Exhibit 9" attached in 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]<<SYS>>Review this pet insurance filing. Company: Accredited Surety and Casualty Company, Inc. Product: ManyPets Pet Insurance Program State: Hawaii Date: 01/23/2023 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] 1) It is noted that your actuarial memo represents that there are not policyholders in the State of Hawaii. Therefore, please provide a countrywide indication. 2) In addition to the trend projection reasoning listed in item 1 of your actuarial memo, please provide a trend projection based on your empirical data. If a trend based on your empirical data not available, please explain why.</s><s>[INST]Generate a response to this objection.[/INST]Response: A countrywide rate indication has been submitted with this response. Response: A trend projection based on our empirical data is not available. The countrywide program incepted on 3/16/2021, with the majority of states not effective until August 2021. Given this small volume of data, a trend projection based on countrywide empirical data is not credible or meaningful. As a result, the Company relied on industry data.</s><s>[INST]Generate another objection to this filing.[/INST]Company Rate Information under the Rate/Rule Schedule tab. 1) Normally we require companies to list the Hawaii indication and rate impact. However, as represented in your actuarial memo that there is no policyholders in Hawaii, please complete the Overall % Indicated Change and Overall % Rate Impact columns based on the countrywide book.</s><s>[INST]Generate a response to this objection.[/INST]Response: The requested information has been provided via post submission update.</s>
<s>[INST]<<SYS>>Review this pet insurance filing. Company: AXIS Insurance Company Product: Pet Health State: Hawaii Date: 05/19/2023 Description: Filing Description: Under SERFF Tr Num: AXSS-G132998247, 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 attach a finalized version of your form under the Form Schedule of SERFF. Currently there are no attachments.</s><s>[INST]Generate a response to this objection.[/INST]I apologize for the oversight. Please see form attached.</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: Trisura Insurance Company Product: Pet Health Insurance State: Hawaii 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 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 rates, rules and forms for use with its new Pet Health Insurance Program. The proposed rates, rules and 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] Please justify your Commission expense selection.</s><s>[INST]Generate a response to this objection.[/INST]The selected Commission is for this program only. The other types of Inland Marine products for Trisura have a much lower commission rate.</s><s>[INST]Generate another objection to this filing.[/INST]Per your Objection 2 Item 2 response, we could not locate your coverage and rate/factor comparison as requested. Please provide the location or submit.</s><s>[INST]Generate a response to this objection.[/INST]We have attached a comparison for the forms and rate/factor for your review and approval.</s><s>[INST]Generate another objection to this filing.[/INST]In Objection 1 Item 1, you acknowledged your understanding the Hawaii Insurance Division does not accept adoption by reference or "me too" filings. In your Objection 2 Item 4 response, you reference an actuarial memorandum in another filing to justify your selections are appropriate. Again, your filing must contain all the necessary supporting material in this SERFF record. We do not permit adoption by reference. If you want to reference supporting material in other filings, you must provide a copy of said filings and highlight/notate the appropriate sections. Please amend your Objection 2 Item 4 response accordingly.</s><s>[INST]Generate a response to this objection.[/INST]We have attached the complete Clear Blue filing. Please reference pages 57-62 for the actuarial supporting documentation.</s><s>[INST]Generate another objection to this filing.[/INST]This filing does not contain the required documentation pursuant the Hawaii General Instructions and could have been returned upon submission. For our continued review, please address the following: 1) Acknowledge that Trisura and Martin have reviewed the Hawaii General Instructions. 2) Provide the required documentation pursuant the Instructions. The Actuarial Memorandum should speak to the competitor rate development, consistency of that method with ASOPs, and why the provisions are appropriate for your company.</s><s>[INST]Generate a response to this objection.[/INST]1) Acknowledge 2) The actuarial information has been attached.</s><s>[INST]Generate another objection to this filing.[/INST]Please confirm you have no active Hawaii policyholders for this product.</s><s>[INST]Generate a response to this objection.[/INST]The company confirms there are no active Hawaii policyholders for this product.</s>
<s>[INST]<<SYS>>Review this pet insurance filing. Company: Independence American Insurance Company Product: 2023 VERSION 4 State: Hawaii Date: 05/05/2023 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] To complete this filing, please submit a Post Submission Update and provide updated effective dates, backdating is not permitted.</s><s>[INST]Generate a response to this objection.[/INST]The effective dates have been amended through a post-submission update.</s><s>[INST]Generate another objection to this filing.[/INST]Thank you for your response 2 dated 6.1.23, please provide the following additional information. 1) We are unable to locate an investment income development, the following objection still stands. An investment income calculation and an illustration or calculation that shows how it is being applied to the rate development. 2) It is unclear how your expense selection were developed in your exhibit 1. Your exhibit 3 does not intuitively explain your selections. Please explain how your Exhibit 1 expense selections were developed.</s><s>[INST]Generate a response to this objection.[/INST]1) Please see the attached Exhibits 2a and 2b. 2) Please see the attached Exhibits 1 and 3 for additional explanation for how the expense selections were developed.</s><s>[INST]Generate another objection to this filing.[/INST]The Declaration section of your application does not appear to be in compliance with Hawaii Revised Statutes §431:10-209. Please revise your application or explain how it is in compliance.</s><s>[INST]Generate a response to this objection.[/INST]The Application has been amended to be compliant with the statute</s><s>[INST]Generate another objection to this filing.[/INST]Please provide a completed Forms Certification located under the Supporting Documentation tab of SERFF.</s><s>[INST]Generate a response to this objection.[/INST]The Forms Certification has been uploaded to the Supporting Documentation tab.</s>
<s>[INST]<<SYS>>Review this pet insurance filing. Company: Liberty Insurance Underwriters Inc. Product: Pet Insurance State: Iowa Date: 10/11/2022 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, and 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] Mandatory arbitration clause. IA law prohibits such clauses in contracts of adhesion. Please remove the clause or make arbitration voluntary. Thanks</s><s>[INST]Generate a response to this objection.[/INST]In response to your objection that IA Statutes S. 679A.1 prohibits mandatory arbitration clauses in contracts of adhesion, the Company respectfully submits in response for your review the controlling Iowa Supreme Court case finding that The Federal Arbitration Act (FAA) preempts IA Statutes S. 679A.1 and provides for arbitration agreements, including those in contracts of adhesion, to be valid and enforceable. See Heaberlin Farms, Inc. v. IGF Ins. Co., 641 N.W.2d 816, 823 (Iowa 2002). In Heaberlin, the Iowa Supreme Court, consistent with substantial Federal case law, found: The FAA does not exclude adhesion contracts. The Iowa statute, by excluding adhesion contracts, is in conflict with the FAA. Thus, if the federal act is applicable, it preempts the Iowa statute by operation of the Supremacy Clause. Heaberlin argues that the federal act is not applicable here because this contract is not a "transaction involving commerce." That is the key issue in this case. Heaberlin at 819. Heaberlin specifically involved a dispute over whether an insurer could enforce an arbitration clause contained within an insurance policy. Heaberlin at 817. The Iowa Supreme Court ruled that the insurer could enforce such an arbitration agreement finding specifically that insurance agreements have a sufficient nexus with interstate commerce to be subject to the Federal Arbitration Act (Heaberlin at 823.) and holding: As the federal act applies, and is in conflict with the provisions of our state arbitration statute exempting adhesion contracts, it was error for the district court to refuse to enforce the arbitration clause. Heaberlin at 823. In light of the above, the Company respectfully submit that IA Statutes S. 679A.1 may not be the grounds for disapproval of the pending form filing.</s>
<s>[INST]<<SYS>>Review this pet insurance filing. Company: Metropolitan General Insurance Company Product: Pet Insurance Plans State: Illinois Date: 10/05/2022 Description: Filing Description: SERFF Tracking #: META-133421781 State Tracking #: Company Tracking #: NY20-83 (FORM) CR State: Illinois Filing Company: Metropolitan General Insurance Company TOI/Sub-TOI: 09.0 Inland Marine/09.0004 Pet Insurance Plans Product Name: Pet Insurance Plans Project Name/Number: PET21END-01-V IL /NY20-83 (Form) CR PDF Pipeline for SERFF Tracking Number META-133421781 Generated 10/13/2022 12:28 A <</SYS>> Generate an objection to this filing.[/INST] Is this an individual policy or a group one? It does make a difference. Thank you.</s><s>[INST]Generate a response to this objection.[/INST]This endorsement is being filed for use with a previously approved individual policy.</s><s>[INST]Generate another objection to this filing.[/INST]What is the Edition Date for this new form? There isn't one on it.</s><s>[INST]Generate a response to this objection.[/INST]We apologize for the oversight. We have revised the form number to include an edition date. The form number is now: PET21END-01-V IL 10-22. This is the only change that we made to the form. I have included a redline version of the form on the Supporting Documentation tab.</s>
<s>[INST]<<SYS>>Review this pet insurance filing. Company: American Modern Home Insurance Company d.b.a. American Modern Insurance Company in CA Product: Pet Insurance Program State: Illinois Date: 08/01/2022 Description: Filing Description: American Modern Home Insurance Company presents a form revision 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] Thank you for your patience while my management team reviewed your response. Your company is assuming that a veterinarian will do something unethical if they treat their own pet or are going to profit in some manner. First, veterinarians take an oath just like human doctors. To break that oath would be the loss of their license to practice, which would mean the loss of the what might be their family's only income. Second, as long as the veterinarian isn't charging a fee that is out of line with what is currently being charged by other veterinarians in their area, how are they profiting? By treating their own pet instead of a paying client's animal, they are actually losing money if they don't charge for the same services. This is no different than an auto owner repairing their own vehicle because they work for an auto body shop. In that instance, the insurance company is only going to pay what is the normal charge for that type of work in the insured's area or what their preferred shop would charge. Since there aren't any "preferred veterinarians," your company would reimburse for the veterinarian services that are common for the area. The answer to your question of "Could we update the exclusion wording to read as, 'Cost for the exam or surgical procedure performed by a Veterinary Provider for his/her own cat or dog.'" is no. Your company cannot exclude the services provided by a veterinarian if they treat their own pet. My objection stands. Your company must either change the wording, withdraw the form or withdraw the entire filing or I will have to recommend this for disapproval.</s><s>[INST]Generate a response to this objection.[/INST]Thank you for your consideration. The Exclusion 17 listed in the Accident Only Policy Form (PAC00) and Exclusion 18 listed in the Full Coverage Pet Health Insurance Policy Form (PET00), Professional fees and services performed by a Veterinary Provider for his/her own cat or dog; has been removed from each policy via the Amendatory Endorsements. Please see the attached Illinois Amendatory Endorsements PAC12 (202207) and PET12 (202207) with the Exclusion Removed.</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]PART IV- EXCLUSIONS - 17. Professional fees and services performed by a Veterinary Provider for his/her own cat or dog; I reviewed your responses to Objections #3 and 8. You are excluding services provided by the insured by refusing to reimburse for a claim for professional fees and services. Additionally, by excluding this, you are forcing an insured to drive somewhere to have their animal treated in what could be a life-threatening situation. For example, there are small rural towns in Illinois that are an hour or more away from a vet. That hour could be the difference between saving the animal and losing it. As I stated previously and notified your company about in an email directly to them, the Department is no allowing this. My objection stands. After management review, it has been decided that we will no longer allow any exclusionary wording that restricts who treats an animal as long as they are accredited and properly licensed in the state of Illinois. Exclusions are allowed for claims that are determined to be fraudulent, but it is inappropriate to assume a specific class of policyholders will act in a fraudulent manner. Moreover, the wording arbitrarily excludes not only current insureds but also other Illinois consumers who might be interested in purchasing animal coverage of any kind. The Departments considers the exclusion to violate 215 ILCS 5/143(2), by containing exceptions and conditions that will unreasonably or deceptively affect the risks that are purported to be assumed by the policy. Therefore, the Department respectfully requests you remove this type of exclusionary wording from every form that includes it and submit it to the Department for compliance review. This applies to all property and casualty lines of business.</s><s>[INST]Generate a response to this objection.[/INST]Thank you for your response. We believe that there still might be some confusion as to what the exclusion is actually excluding. We agree that any veterinarian may provide treatment to any pet. We do not want to cause harm or restrict treatment resources for a pet that is in need of services. However, we want to reserve the right to not reimburse a veterinarian who charges themselves for doing a surgery on their own pet. They will end up profiting from the insurance coverage in a situation like one outlined above as veterinarians often share clinic profits as a portion of their salary. We will cover all drug fees, materials, supplies, etc. we are only saying we would restrict the coverage to not pay for the exam or surgical procedure a pet had done by its owner. Could we update the exclusion wording to read as, Cost for the exam or surgical procedure performed by a Veterinary Provider for his/her own cat or dog. Thank you in advance for your consideration.</s><s>[INST]Generate another objection to this filing.[/INST]Please confirm that form does not become part of the policy. If it does, it needs to be submitted under the Form Schedule along with the appropriate EFT.</s><s>[INST]Generate a response to this objection.[/INST]Yes, this form has been updated to show under the Form Schedule along with the appropriate EFT.</s><s>[INST]Generate another objection to this filing.[/INST]8. (p10 or 11) I reviewed your 09/23/2022 response to Objection #10 and the form again. Thank you for confirming the 60 days mailing for the renewal notice. My question is regarding the change in policy and issuing a new policy. Why aren't you adding an endorsement or issuing a new dec for the change in coverage? By issuing a new policy instead of endorsing an existing one, the insured never builds up a relationship with your company or, possibly, a payment or credit history. Do you issue a new policy when a decrease it requested? The form states that at there isn't a reset for a decrease in coverage, but it doesn't address the issuance of a new policy. SERFF Tracking #: AMMH-133347090 State Tracking #: Company Tracking #: 20220616-04 State: Illinois Filing Company: American Modern Home Insurance Company d.b.a. American Modern Insurance Company in CA TOI/Sub-TOI: 09.0 Inland Marine/09.0004 Pet Insurance Plans Product Name: Pet Insurance Program Project Name/Number: Form Revision/20220616-04 PDF Pipeline for SERFF Tracking Number AMMH-133347090 Generated 10/18/2022 06:29 PM</s><s>[INST]Generate a response to this objection.[/INST]That is correct, we do not reset a policy for a decrease in coverage. As mentioned before when policy coverage increases happen, the policys waiting period and the determination of pre-existing conditions reset as of the date of the coverage change. However, We have found that though policy increases are not common, when they do happen, policyholders understand the process and are happy with the additional coverage and the retention rate is the same or similar to other non-altered policies.</s><s>[INST]Generate another objection to this filing.[/INST]Taxes and Fees - Please address each of these separately. 1. What fees, taxes, and/or surcharges in Illinois would be included here? The Department needs to know what these would be if the consumer is being charged for them. Additionally, Illinois does expect the consumer to be told what these are prior to the policy being issued. 2. If any of the fees exceed 10% of the premium amount, then the consumer must accept and sign confirming they are aware. 3. If this is a nationwide form and these are not applicable to Illinois, what do you include in this area on this form?</s><s>[INST]Generate a response to this objection.[/INST]1.There would only be two fees that would be shown here. These include the Administrative Fee which is charged to policyholders with the first transaction when enrolling their first pet. The second fee that would be shown here is the Monthly Installment Fee. This fee is $1 and charged on a monthly basis. A policyholder would only be charged this if they choose to pay their premium in monthly installments instead of a one time annual charge. 2.The Administrative Fee and the Monthly Installment Fee are listed on the policy quote prior to the policy being created. At this point the policyholder has the opportunity to review the total policy premium, confirm and purchase the policy by agreeing to the policy terms/conditions. 3.This form is a countrywide form. However, for the state of Illinois the only two fees that would be listed on the Declarations Page is the Administrative Fee and the Monthly Installment Fee.</s><s>[INST]Generate another objection to this filing.[/INST]PART VII - HOW TO FILE A CLAIM Please explain why your company would be notifying a former insured about a claim on "your MyEmbrace customer portal." They aren't a customer if their policy is no longer active. Does your company keep their access open after a policy is cancelled/non- renewed? Are you not covering claims that occurred during a policy term if they submit it within 60 days after the policy ends? Illinois expects a claim that occurred during a policy term to be processed by the insurance company, especially if they're notified as soon as possible after the claim occurred. In this instance, the customer may have been waiting for all of the paperwork from their vet's office so they could submit it all at one time.</s><s>[INST]Generate a response to this objection.[/INST]Yes, the company does keep their access open after a policy is cancelled/nonrenewed. As long as the claim (invoice) has been submitted in the 60 days after the term ends, the claim can still be processed. Embrace must receive FNOL in that 60-day period. Even if it takes a year to collect needed docs, as long as FNOL was received on time, the claim can be processed. All we need to start a claim is FNOL, which is usually a claim form or invoice. Invoice is always available at the time of service, so there should be no issue with collecting that documentation for the FNOL.</s><s>[INST]Generate another objection to this filing.[/INST]PART IV - EXCLUSIONS - 18. Professional fees and services performed by a Veterinary Provider for his/her own cat or dog; (p8) It has come to the Department's attention that we have been allowing exclusionary wording that assumes an insured would act in a fraudulent manner. After management review, it has been decided that we will no longer allow any exclusionary wording that restricts who treats an animal as long as they are accredited and properly licensed in the state of Illinois. Exclusions are allowed for claims that are determined to be fraudulent, but it is inappropriate to assume a specific class of policyholders will act in a fraudulent manner. Moreover, the wording arbitrarily excludes not only current insureds but also other Illinois consumers who might be interested in SERFF Tracking #: AMMH-133347090 State Tracking #: Company Tracking #: 20220616-04 State: Illinois Filing Company: American Modern Home Insurance Company d.b.a. American Modern Insurance Company in CA TOI/Sub-TOI: 09.0 Inland Marine/09.0004 Pet Insurance Plans Product Name: Pet Insurance Program Project Name/Number: Form Revision/20220616-04 PDF Pipeline for SERFF Tracking Number AMMH-133347090 Generated 10/18/2022 06:29 PM purchasing animal coverage of any kind. The Departments considers the exclusion to violate 215 ILCS 5/143(2), by containing exceptions and conditions that will unreasonably or deceptively affect the risks that are purported to be assumed by the policy. Therefore, the Department respectfully requests you remove this type of exclusionary wording from every form that includes it and submit it to the Department for compliance review. This applies to all property and casualty lines of business. I have also including this information in an email to the company contact listed on this filing.</s><s>[INST]Generate a response to this objection.[/INST]In the objection it is mentioned that the state of Illinois will no longer allow any exclusionary wording that restricts who treats an animal as long as they are accredited and properly licensed in the state of Illinois. The exclusion 18 does not restrict who performs the service on the animal, but excludes the coverage of professional fees and services.</s><s>[INST]Generate another objection to this filing.[/INST]Part VI - 17. (p3) How are you in compliance regarding the insured withdrawing their consent for electronic delivery of forms? 215 ILCS 5/143.34 A notice or document may be delivered by electronic means by an insurer to a party under this Section if: (1) the party has affirmatively consented to that method of delivery and has not withdrawn the consent; (2) the party, before giving consent, is provided with a clear and conspicuous statement informing the party of: (A) the right of the party to withdraw consent to have a notice or document delivered by electronic means, at any time, and any conditions or consequences imposed in the event consent is withdrawn; (B) the types of notices and documents to which the party's consent would apply; (C) the right of a party to have a notice or document delivered in paper form; and (D) the procedures a party must follow to withdraw consent to have a notice or document delivered by electronic means and to update the party's electronic mail address; (3) the party: (A) before giving consent, is provided with a statement of the hardware and software requirements for access to, and retention of, a notice or document delivered by electronic means; and (B) consents electronically, or confirms consent electronically, in a manner that reasonably demonstrates that the party can access information in the electronic form that will be used for notices or documents delivered by electronic means as to which the party has given consent.</s><s>[INST]Generate a response to this objection.[/INST]This electronic delivery disclosure and consent is presented prior to purchase and acknowledged via a check box. If a pet parent (policyholder) advises they want to receive their information by mail instead, we will mail all policy documents at new business and renewal.</s><s>[INST]Generate another objection to this filing.[/INST]Procedure - 3. Complaints (last page of each form) 215 ILCS 5/143c. No insurance policy authorized under Class 1, 2 or 3 of Section 4 of this Code shall be delivered in this State unless the policyholder or certificate holder is provided written notice of: (1) the address of the complaint department of the insurance company; and (2) the address of the Public Service Division of the Department of Insurance or its successor. 1. Please add the Springfield office's address because that is the main office for the Department. Thank you. Illinois Department of Insurance P&C Consumer Complaints 320 W Washington St Springfield, IL 62767 2. Since your company is asking the insured to consent to electronic delivery of notices, we respectfully request that you include the Department's online information also. Here is the information for submitting an online complaint and how to reach the complaint forms to print off and mail/fax to us: SERFF Tracking #: AMMH-133347090 State Tracking #: Company Tracking #: 20220616-04 State: Illinois Filing Company: American Modern Home Insurance Company d.b.a. American Modern Insurance Company in CA TOI/Sub-TOI: 09.0 Inland Marine/09.0004 Pet Insurance Plans Product Name: Pet Insurance Program Project Name/Number: Form Revision/20220616-04 PDF Pipeline for SERFF Tracking Number AMMH-133347090 Generated 10/18/2022 06:29 PM https://mc.insurance.illinois.gov/messagecenter.nsf (online form) https://www2.illinois.gov/sites/Insurance/Consumers/Documents/PropertyCasualtyComplaintForm.pdf (printable format)</s><s>[INST]Generate a response to this objection.[/INST]Please see the updated attached form under the Supporting Documentation tab; IN084 07/20 has been replaced with the new edition of IN084 (09/22).</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]PART IV - EXCLUSIONS - 17. Professional fees and services performed by a Veterinary Provider for his/her own cat or dog; (p7) It has come to the Department's attention that we have been allowing exclusionary wording that assumes an insured would act in a fraudulent manner. After management review, it has been decided that we will no longer allow any exclusionary wording that restricts who treats an animal as long as they are accredited and properly licensed in the state of Illinois. Exclusions are allowed for claims that are determined to be fraudulent, but it is inappropriate to assume a specific class of policyholders will act in a fraudulent manner. Moreover, the wording arbitrarily excludes not only current insureds but also other Illinois consumers who might be interested in purchasing animal coverage of any kind. The Departments considers the exclusion to violate 215 ILCS 5/143(2), by containing exceptions and conditions that will unreasonably or deceptively affect the risks that are purported to be assumed by the policy. Therefore, the Department respectfully requests you remove this type of exclusionary wording from every form that includes it and submit it to the Department for compliance review. This applies to all property and casualty lines of business. I have also including this information in an email to the company contact listed on this filing.</s><s>[INST]Generate a response to this objection.[/INST]In the objection it is mentioned that the state of Illinois will no longer allow any exclusionary wording that restricts who treats an animal as long as they are accredited and properly licensed in the state of Illinois. The exclusion 18 does not restrict who performs the service on the animal, but excludes the coverage of professional fees and services.</s><s>[INST]Generate another objection to this filing.[/INST]PART II - CONDITIONS - 2. (p1 or 4) It has come to the Department's attention that we have been allowing exclusionary wording that assumes an insured would act in a fraudulent manner. After management review, it has been decided that we will no longer allow any exclusionary wording that restricts who treats an animal as long as they are accredited and properly licensed in the state of Illinois. Exclusions are allowed for claims that are determined to be fraudulent, but it is inappropriate to assume a specific class of policyholders will act in a fraudulent manner. Moreover, the wording arbitrarily excludes not only current insureds but also other Illinois consumers who might be interested in purchasing animal coverage of any kind. The Departments considers the exclusion to violate 215 ILCS 5/143(2), by containing exceptions and conditions that will unreasonably or deceptively affect the risks that are purported to be assumed by the policy. SERFF Tracking #: AMMH-133347090 State Tracking #: Company Tracking #: 20220616-04 State: Illinois Filing Company: American Modern Home Insurance Company d.b.a. American Modern Insurance Company in CA TOI/Sub-TOI: 09.0 Inland Marine/09.0004 Pet Insurance Plans Product Name: Pet Insurance Program Project Name/Number: Form Revision/20220616-04 PDF Pipeline for SERFF Tracking Number AMMH-133347090 Generated 10/18/2022 06:29 PM Therefore, the Department respectfully requests you remove this type of exclusionary wording from every form that includes it and submit it to the Department for compliance review. This applies to all property and casualty lines of business. I have also including this information in an email to the company contact listed on this filing. *Please note that I am including this on both of these forms in case Form PETCP is not used with Form PET00.</s><s>[INST]Generate a response to this objection.[/INST]Please see the updated form PET12 (07/22) with this language removed. Please see the new state specific form PCPIL (09/22) Claims Process Endorsement Illinois attached. This form is replacing the form PETCP (03/21) Claims Process Endorsement.</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]8. (p10 or 11) I have a few concerns with this section. Please address each of them separately. 1. I understand your company will need to underwrite most changes to a policy. My concern is with your company's decision to start the Waiting Period and Pre-existing Conditions over for the entire policy. Why aren't you only doing that for the change? For example, the original policy had an Annual Maximum of $5,000, and the insured requests a change to $7,500. Why aren't you only starting the Waiting Period and Pre-existing Conditions over on the $2,500 increase? 2. Please confirm that your company will mail the renewal notice with the changes at least 60 days prior to the renewal or anniversary date. 215 ILCS 5/143.17</s><s>[INST]Generate a response to this objection.[/INST]1.When a pet parent increases the Pets Coverage amount, the policys waiting period and the determination of pre-existing conditions reset as of the date of the coverage change. The policy is cancelled and re-written in order to capture the waiting period due to the increase in coverage. 2. This is confirmed. The Renewal notice with changes is mailed at least 60 days prior to the renewal or anniversary date.</s><s>[INST]Generate another objection to this filing.[/INST]PART II - CONDITIONS - 2. (p4) It has come to the Department's attention that we have been allowing exclusionary wording that assumes an insured would act in a fraudulent manner. After management review, it has been decided that we will no longer allow any exclusionary wording that restricts who treats an animal as long as they are accredited and properly licensed in the state of Illinois. Exclusions are allowed for claims that are determined to be fraudulent, but it is inappropriate to assume a specific class of policyholders will act in a fraudulent manner. SERFF Tracking #: AMMH-133347090 State Tracking #: Company Tracking #: 20220616-04 State: Illinois Filing Company: American Modern Home Insurance Company d.b.a. American Modern Insurance Company in CA TOI/Sub-TOI: 09.0 Inland Marine/09.0004 Pet Insurance Plans Product Name: Pet Insurance Program Project Name/Number: Form Revision/20220616-04 PDF Pipeline for SERFF Tracking Number AMMH-133347090 Generated 10/18/2022 06:29 PM Moreover, the wording arbitrarily excludes not only current insureds but also other Illinois consumers who might be interested in purchasing animal coverage of any kind. The Departments considers the exclusion to violate 215 ILCS 5/143(2), by containing exceptions and conditions that will unreasonably or deceptively affect the risks that are purported to be assumed by the policy. Therefore, the Department respectfully requests you remove this type of exclusionary wording from every form that includes it and submit it to the Department for compliance review. This applies to all property and casualty lines of business. I have also including this information in an email to the company contact listed on this filing.</s><s>[INST]Generate a response to this objection.[/INST]Please see the updated form PAC12 (07/22) with this language removed.</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: Illinois Date: 11/17/2022 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 associated module; this form was originally approved under CRUM-131553267 and withdrawn in CRUM-132957659. There are no changes to the originally approved form aside from edition date; a redline copy has been provided for reference. <</SYS>> Generate an objection to this filing.[/INST] The objection I had on this form on SERFF Tracking Number CRUM-131553267 still applies to this version of this form. What policy (or policies) does (do) this form endorse? That information needs to be included on it..</s><s>[INST]Generate a response to this objection.[/INST]We apologize for the oversight; the correct form version has been uploaded to the Form Schedule tab.</s><s>[INST]Generate another objection to this filing.[/INST]FYI: According to your General Information, "a redline copy has been provided for reference." The copy submitted under the Supporting Documentation tab is not redlined or highlighted in any manner.</s><s>[INST]Generate a response to this objection.[/INST]Thank you! A corrected redline version of the proper form has been uploaded.</s>
<s>[INST]<<SYS>>Review this pet insurance filing. Company: American Pet Insurance Company Product: Trupanion State: Illinois Date: 08/19/2022 Description: Filing Description: American Pet Insurance Company (“APIC”) is submitting this form filing to introduce a new pet health insurance plan for all newly enrolled pets. All currently enrolled pets will remain on the approved Trupanion pet health plan. The Explanatory Memorandum attached to the Supporting Documentation tab highlights the key differences between this new plan and the existing plan. <</SYS>> Generate an objection to this filing.[/INST] Enrollment Path Please review the following statute and the Department's Company Bulletin 2012-11. After you review all of it, please explain why your company feels you are in compliance with each one. Thank you. 215 ILCS 5/151: Payment or acceptance of rebates prohibited. (1) No company doing business in this State and no insurance agent or broker shall offer, promise, allow, give, set off or pay, directly or indirectly, any rebate of or part of the premium payable on the policy, or on any policy or agent's commission thereon or earnings, profits, dividends or other benefits founded, arising, accruing or to accrue thereon or therefrom, or any special advantage in date of policy or age of issue, or any paid employment or contract for services of any kind or any other valuable consideration or inducement to or for insurance on any risk in this State, now or hereafter to be written, or for or upon any renewal of any such insurance, which is not specified in the policy contract of insurance, or offer, promise, give, option, sell, purchase any stocks, bonds, securities or property or any dividends or profits accruing or to accrue thereon, or other thing of value whatsoever as inducement to insurance or in connection therewith, or any renewal thereof which is not specified in the policy. Nothing in this Section shall prevent a company from paying a bonus to policyholders or otherwise abating their premiums in whole or in part out of surplus accumulated from nonparticipating insurance nor prevent a company which transacts industrial life insurance on a weekly payment plan from returning to policyholders who have made premium payments for a period of at least one year directly to the company at its home or district offices the percentage of premium which the company would otherwise have paid for the weekly collection of such premium nor shall this Section be construed to prevent the taking of a bona fide obligation, with interest at six per centum per annum, in payment of any premium. Nothing in this Section shall prevent a company from offering a child passenger restraint system or a discount from the purchase price of a child passenger restraint system to policyholders, when the purpose of such restraint system is the safety of a child and compliance with the "Child Passenger Protection Act", approved June 27, 1983, as amended. (2) No insured person or party or applicant for insurance shall directly or indirectly receive or accept, or agree to receive or accept any rebate of premium or of any part thereof or all or any part of any agent's or broker's commission thereon, or any favor or advantage, or share in any benefit to accrue under any policy of insurance, or any valuable consideration or inducement, other than such as is specified in the policy. 215 ILCS 5/500-80: Sec. 500-80. Commissions. (a) An insurer or insurance producer may not pay a commission, service fee, brokerage, or other valuable consideration to a SERFF Tracking #: APII-133352477 State Tracking #: Company Tracking #: APIC-TRUC-IL202206-F State: Illinois Filing Company: American Pet Insurance Company TOI/Sub-TOI: 09.0 Inland Marine/09.0004 Pet Insurance Plans Product Name: Trupanion Project Name/Number: / PDF Pipeline for SERFF Tracking Number APII-133352477 Generated 01/16/2023 12:31 AM person for selling, soliciting, or negotiating insurance in this State if that person is required to be licensed under this Article and is not so licensed at the time of selling, soliciting, or negotiating the insurance. (b) A person may not accept a commission, service fee, brokerage, or other valuable consideration for selling, soliciting, or negotiating insurance in this State if that person is required to be licensed under this Article and is not so licensed. (c) Renewal or other deferred commissions may be paid to a person for selling, soliciting, or negotiating insurance in this State if the person was required to be licensed under this Article at the time of the sale, solicitation, or negotiation and was so licensed at that time. (d) An insurer or insurance producer may pay or assign commissions, service fees, brokerages, or other valuable consideration to an insurance agency or to persons who do not sell, solicit, or negotiate insurance in this State, unless the payment would violate Section 151 of this Code. (e) When an insurance producer or business entity charges any fee or compensation separate from commissions deductible from, or directly attributable to, premiums on insurance policies or contracts, it must comply with all of the following: (1) It must provide written disclosure to the consumer or contracting party that clearly specifies the amount or extent of the compensation or fee prior to the delivery of the corresponding policy. A copy of the written disclosure must be maintained by the producer or business entity that collects the compensation or fee for a period of 7 years. (2) If the combined compensation or fee exceeds 10% of a directly attributable premium amount of a corresponding contract or policy, the disclosure must also include the signature of the consumer or contracting party acknowledging the compensation or fee. (3) If an insurance policy or contract is cancelled for any reason within 90 days following the inception date, the producer or business entity shall refund to the consumer a prorated portion of the fee or compensation within 30 days after the producer or business entity receives proper documentation that the corresponding insurance policy or contract has been cancelled. At no time shall a producer or business entity charge the consumer a fee or compensation for cancellation of any insurance policy or contract. (4) If the policy file contains documentation that the producer performed a service corresponding to the applicable coverage or policy and the written disclosure stated that the fees were fully earned, then those fees shall be fully earned at inception of the disclosure's execution.</s><s>[INST]Generate a response to this objection.[/INST]Thank you for the legal citation. We do not read this statute as prohibiting referral fees, which we see as distinct from rebating or rewards contingent on the sale of insurance. We respectfully request a call with the Departments market conduct and/or legal teams to discuss our reading of this statute and our referral program. We will make ourselves available at the Departments convenience.</s><s>[INST]Generate another objection to this filing.[/INST]I reviewed your 11/29/2022 response to Objection #1 regarding "earn rewards" and "successful referral." Your response was "a successful referral occurs when the referred pet owner obtains a quote, and does not require the referred pet owner actually purchases a policy." My objection stated "Illinois does not allow for compensation for referrals based on whether or not a referred person APPLIES for insurance." An insured cannot be paid for a referral in Illinois. It does not matter whether the referred person actually purchases the policy or not. This program pays the insured to refer people to your company. My objection stands. This needs to be removed.</s><s>[INST]Generate a response to this objection.[/INST]Please see "Responses to Objections Received on November 30, 2022" 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]"After Your plan has been in effect for 60 days, We may also cancel this plan if:" (p3) Thank you adding this wording, but why didn't you include the remaining wording from 215 ILCSZ 5/143.16a?</s><s>[INST]Generate a response to this objection.[/INST]Please see "Responses to Objections Received on November 30, 2022" 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]Objection #4 response FYI: Please note that Illinois will not be adopting the NAIC Pet Insurance Model Law at this time.</s><s>[INST]Generate a response to this objection.[/INST]Please see "Responses to Objections Received on November 30, 2022" 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]5 EP2.1 Checkout Complete pdf You have a section on this screenshot called "Earn rewards." It states that the insured would receive $25 for each "successful referral." Illinois does not allow for compensation for referrals based on whether or not a referred person applies for insurance. This would be considered commission and can only be paid to a licensed producer. Therefore, this entire program will need to be removed.</s><s>[INST]Generate a response to this objection.[/INST]Please see "Responses to Objections Received November 15, 2022" 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]Your right to appeal cancellation or non-renewal (p3) Our Legal area has determined that hearings are not allowed for a non-renewal of personal inland marine policy. They are available on a cancellation. Therefore, all references to a hearing on a non-renewal must be removed. Thank you.</s><s>[INST]Generate a response to this objection.[/INST]Please see "Responses to Objections Received November 15, 2022" 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]V. and VI. (p10) 1. Before your company cancels a policy because you didn't receive all the medical records, do you contact the insured? If you're not, why aren't you? You might be cancelling the policy, and the insured has no idea there's a problem. 2. Are there any provisions in place if the reason you haven't received all the medical records is because a veterinarian or veterinary hospital hasn't provided the records by the date requested? The insured has no control over how quickly someone outside of their direct control responds to you. 3. 215 ILCS 5/143.16a: After a policy has been in effect for 60 days, insurer may only cancel for the following 6 reasons: (a) non- payment of premium; (b) the policy was obtained through a material misrepresentation; (c) any insured violated any terms and conditions of the policy; (d) the risk originally accepted has measurably increased; (e) the insurer certifies to the Director of the loss of reinsurance for all or a substantial part of the underlying risk; or (f) the Director determines that continuation of the policy could place SERFF Tracking #: APII-133352477 State Tracking #: Company Tracking #: APIC-TRUC-IL202206-F State: Illinois Filing Company: American Pet Insurance Company TOI/Sub-TOI: 09.0 Inland Marine/09.0004 Pet Insurance Plans Product Name: Trupanion Project Name/Number: / PDF Pipeline for SERFF Tracking Number APII-133352477 Generated 01/16/2023 12:31 AM the insurer in violation of Illinois insurance laws. 4. 215 ILCS 5/143.15: Insurers must mail cancellation notice to the named insured and mortgagee or lien holder, if known, at last known mailing address, at least: 10 days prior to the effective date of cancellation for non-payment of premium; and 30 days prior to the effective date of cancellation for any other reason. All notices shall include a specific explanation of the reason(s) for cancellation.</s><s>[INST]Generate a response to this objection.[/INST]Please see "Responses to Objections Received November 15, 2022" 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]What We Don't Cover - A. I. c. (p12) What if the insured's vet diagnosed the pet with a different illness/disease that has similar signs or symptoms prior to the policy being issued. Then, it turns out that the illness/disease was something else, but that diagnosis wasn't made until after the policy was issued. Will you cover it in that instance? I understand why your company wants to exclude these, but the insured can only go by what their veterinarian tells them. Based on this exclusionary wording, your company (1) is assuming that every insured should second-guess their veterinarian and (2) puts a heavy burden on the insured.</s><s>[INST]Generate a response to this objection.[/INST]Please see "Responses to Objections Received November 15, 2022" 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]D. IV. "n within the timeframe recommended by Your Veterinarian.. If Your" (p13) Please remove the second period.</s><s>[INST]Generate a response to this objection.[/INST]Please see "Responses to Objections Received November 15, 2022" 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]XVIII. "including bathing intended as Veterinary Treatment for an eligible Condition" (p15) If it's part of a treatment for an eligible condition and the vet's office does it, why wouldn't you cover it? Some of the medicated shampoos and other treatments have to be done in a veterinarian's office by a trained professional.</s><s>[INST]Generate a response to this objection.[/INST]Please see "Responses to Objections Received November 15, 2022" 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]O. (p19) "Other Insurance" provisions must state that coverage under the policy will share proportionately with other similar coverages the insured may have. Any forms that contain provisions to the contrary are deemed to contain exceptions and conditions that unreasonably or deceptively affect the risks that are purported to be assumed by the policy, in violation of Section 143(2) and will be disapproved accordingly.</s><s>[INST]Generate a response to this objection.[/INST]Please see "Responses to Objections Received November 15, 2022" 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]P. (p19) Please confirm that your company is aware that Illinois requires any policy not in compliance with our laws to be endorsed so they are and that you will comply with this requirement.</s><s>[INST]Generate a response to this objection.[/INST]Please see "Responses to Objections Received November 15, 2022" 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]This is a follow-up to the conversation I had with Justin Compton. Please provide the updated documents that we discussed on 10/12/2022. I understand it will take you a couple of weeks to finalize them. Thank you.</s><s>[INST]Generate a response to this objection.[/INST]Please see "Responses to Objections Received October 20, 2022" 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]Tax (State/Local/Province) MEDICAL RECORDS SUMMARY FEE 1. What taxes in Illinois would be included here? The Department needs to know what these would be if the consumer is being charged for them. Additionally, Illinois does expect the consumer to be told what these are prior to the policy being issued. 2. If any of the fees exceed 10% of the premium amount, then the consumer must accept and sign confirming they are aware. How much is the Medical Records Summary Fee? It is not listed on this form. Is there a difference in the fee for a pet that has only one vet visit (such as a taking a stray in off the streets) and one that has more records (such as adopting from a shelter or animal control)? 3. If this is a nationwide form and these are not applicable to Illinois, what do you include in this area on this form? *I am including this objection since we discussed it too.</s><s>[INST]Generate a response to this objection.[/INST]Please see "Responses to Objections Received October 20, 2022" 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]<<SYS>>Review this pet insurance filing. Company: Independence American Insurance Company Product: 2023 Individual Pet - Forms State: Illinois Date: 09/02/2022 Description: Filing Description: SERFF Tracking #: IAIC-133336736 State Tracking #: Company Tracking #: 2023 INDIVIDUAL PET FORMS - IL State: Illinois Filing Company: Independence American Insurance Company TOI/Sub-TOI: 09.0 Inland Marine/09.0004 Pet Insurance Plans Product Name: 2023 Individual Pet - Forms Project Name/Number: SPOT/NEW PRODUCT FILING-2023 INDIVIDUAL PDF Pipeline for SERFF Tracking Number IAIC-133336736 Generated 03/01/2023 01:12 A <</SYS>> Generate an objection to this filing.[/INST] I reviewed your 02/08/2023 response to Objection #1. The answer to you question is yes. Thank you.</s><s>[INST]Generate a response to this objection.[/INST]Thank you for your review. At your request we have reverted the language to that which was originally submitted.</s><s>[INST]Generate another objection to this filing.[/INST]I was just notified that a change was made overnight to the Department's website. Unfortunately, the link I gave one no longer works. I am very sorry about this. I was not aware they were moving the form. Please change the link for the complaint forms to print off and mail/fax to us to: https://idoi.illinois.gov/content/dam/soi/en/web/insurance/sites/insurance/consumers/documents/propertycasualtycomplaintform.pdf</s><s>[INST]Generate a response to this objection.[/INST]The website link has been revised.</s><s>[INST]Generate another objection to this filing.[/INST]I reviewed your 02-08-2023 response to Objection #7. Please correct me if I'm wrong. You only allow an insured to make some changes at renewal, which would include things such as increasing their deductible or coinsurance. However, you allow mid-term changes to coverage. Several pet insurance filings I have reviewed only allow coverage changes at renewal and some only allow any changes at renewal. The way your company does it seems backwards to me. Either way, it doesn't answer the question as to why a new policy has to be issued. My objection stands.</s><s>[INST]Generate a response to this objection.[/INST]We are unclear as to your objection. Any changes that the Policyholder requests must be reviewed and approved by us. Some changes will be allowed only at renewal (such as dropping Preventive Care coverage under a rider if the benefit has already been paid during the coverage period). Some changes, regardless of whether they are requested by the policyholder at renewal or during the coverage period, require a new enrollment, in order to mitigate risk and to deter potential fraud. Based on your comments, we have reviewed Illinois insurance statutes, regulations, and guidance, and despite our best efforts we are unable to locate a requirement with force of law that would serve to limit an insurers right to require a new policy be issued if a Policyholder is requesting a change in coverage that could impact the risk assumed. As such, we request that you direct us to a relevant citation so that we may ensure and confirm full compliance and revise our forms accordingly, if necessary. </s><s>[INST]Generate another objection to this filing.[/INST]1. Thank you for working with me on the discount on this filing. I appreciate that. I reviewed this entire filing again and have determined your explanations are acceptable. My objection to your discounts and referrals is withdrawn. 2. You made some changes to these forms on 12/20/2022. Can you please tell me what they are? Nothing in my 12/12/2022 pertained to them specifically, so I need a little guidance on what was changed. Thank you.</s><s>[INST]Generate a response to this objection.[/INST]Your objection on 12/12/2022 requested that we change or remove the wording in question. At that point, we were unclear as to exactly what the wording in question was referring to, and so we requested a meeting with the Department. As you indicated that the Department was unavailable to meet with us prior to the due date of the responses, we made some additional edits to the provisions on page 12 and 13 to provide further clarification as to the intent of our provisions. All edits (shown in the marked redlines attached as supporting documentation submitted on 12/20/2022) were made in an attempt to satisfy the Departments request to change the wording in question. Given your response to #1 above, please let us know if you would like us to revert to the language originally submitted.</s><s>[INST]Generate another objection to this filing.[/INST]Legal Action (p9) 215 ILCS 5/143.1: Any period of time for filing suit against company must be extended by the number of days between the date the proof of loss was filed and the date the claim was denied in whole or in part.</s><s>[INST]Generate a response to this objection.[/INST]Acknowledged. The law requires that the running of the time period for which a policyholder has to file suit must be tolled between the date on which proof of loss is filed until the date the claim is denied in whole or in part. Therefore, the time period for a policyholder to bring suit cannot start to run until the claim has been paid or denied. Please note that the tolling of the time period (between claim submission and claim determination) is built into this provision of the Policy. Our Legal Action provision allows for a minimum of 12 months from the date of the claim determination to take legal action. Since our provision which limits the period within which the policyholder may bring suit does not start to run until the date of the claim determination, no revisions are required to be made to this provision.</s><s>[INST]Generate another objection to this filing.[/INST]Termination (p10) 215 ILCS 5/143.15: Insurers must mail cancellation notice to the named insured and mortgagee or lien holder, if known, at last known mailing address, at least: 10 days prior to the effective date of cancellation for non-payment of premium; and 30 days prior to the effective date of cancellation for any other reason.</s><s>[INST]Generate a response to this objection.[/INST]This provision has been revised to allow for a minimum of 10 and 30 days advance notice in accordance with the above.</s><s>[INST]Generate another objection to this filing.[/INST]Other Insurance (p11) "Other Insurance" provisions must state that coverage under the policy will share proportionately with other similar coverages the insured may have. Any forms that contain provisions to the contrary are deemed to contain exceptions and conditions that unreasonably or deceptively affect the risks that are purported to be assumed by the policy, in violation of Section 143(2) and will be disapproved accordingly.</s><s>[INST]Generate a response to this objection.[/INST]This provision has been revised</s><s>[INST]Generate another objection to this filing.[/INST]Conformity with State Law (p11) Please confirm that your company is aware that Illinois requires any policy not in compliance with our laws to be endorsed so they are and that you will comply with this requirement.</s><s>[INST]Generate a response to this objection.[/INST]We confirm that if at anytime this policy is not in compliance with Illinois law, we will file an endorsement to bring the policy into compliance.</s><s>[INST]Generate another objection to this filing.[/INST]Dual Coverage With Us (p10 or 11) SERFF Tracking #: IAIC-133336736 State Tracking #: Company Tracking #: 2023 INDIVIDUAL PET FORMS - IL State: Illinois Filing Company: Independence American Insurance Company TOI/Sub-TOI: 09.0 Inland Marine/09.0004 Pet Insurance Plans Product Name: 2023 Individual Pet - Forms Project Name/Number: SPOT/NEW PRODUCT FILING-2023 INDIVIDUAL PDF Pipeline for SERFF Tracking Number IAIC-133336736 Generated 03/01/2023 01:12 AM Since you're going to consider the insured to only have one policy in this instance, are you voiding the other policy and refunding the entire premium? If you're not going to pay a claim under the other policy, the premium needs to be refunded completely.</s><s>[INST]Generate a response to this objection.[/INST]You are correct. The company would void the policy that has been in force for the lesser period of time and a refund provided. Additional language has been added to this provision to make it clear to the policyholder.</s><s>[INST]Generate another objection to this filing.[/INST]Is it possible to put the signatures on the first page of this form? It seems a waste of resources to only have signatures on the second page. Thank you.</s><s>[INST]Generate a response to this objection.[/INST]The paragraph alignment are all justified and the bracketed place holders for Insurer and Marketing Name have been removed in order for the signature section to fit on the first page. No other changes have been made.</s><s>[INST]Generate another objection to this filing.[/INST]4. (p3) If your company voids this rider, then the entire premium for the rider must be refunded to the insured not just "the portion of the premium paid during the current Coverage Period for such Covered Pets coverage under this Rider." Since your company would not allow this rider to be added at original issue if the pet had ever been diagnosed with cancer, the entire premium would always need to be refunded when you obtain this information.</s><s>[INST]Generate a response to this objection.[/INST]We have revised the rider language to address your concerns.</s><s>[INST]Generate another objection to this filing.[/INST]"If We elect to non-renew, We will provide You advance written notice of this Riders non-renewal at least [30-60] days p3) 215 ILCS 5/143.17: If, at renewal, the insurer is imposing changes in deductibles or coverage for any policy forms applicable to an entire line of business, then written notice of the changes must be mailed 60 days prior to the renewal or anniversary date. Notice shall also be sent to the insured's broker, if known, or the agent of record.</s><s>[INST]Generate a response to this objection.[/INST]This section has been revised to just 60 days with the inclusion of the policyholders agent if known.</s><s>[INST]Generate another objection to this filing.[/INST]Please correct the Form Number on pages 2 and 3.</s><s>[INST]Generate a response to this objection.[/INST]This typo has been corrected on page 2 and 3. In addition, the form number was revised to be state specific replacing the XX with IL.</s><s>[INST]Generate another objection to this filing.[/INST]I sent your company response to the Producer Regulatory Investigations supervisor to review. Here are his and my objections on this filing. 1. I am not an expert on this subject, but the supervisor over that unit is. He reviewed your 12/08/2022 response to my objection. It was determined that you are still bordering on rebating. You must change or remove the wording. 2. You also stated in your response "There is no law that requires all policyholders in Illinois to be treated the same." In addition to statutes and regulations in Illinois, the Department has a historical stance. The Department expects ALL consumers and policyholders in Illinois to be treated the same. We have always required that, and I see no change to that in the future. You also quoted two sections of that only deal with rates. Since this is a form filing, they do not apply. I understand your company's position. However, even if we allowed the unfair treatment of policyholders in this instance, your company is still bordering on rebating. Because of this, there are only three options available to your company. 1. Change or remove the wording in question; 2. Withdraw the form or 2. I discuss recommending this filing for disapproval with my manager. She will review this entire filing and discuss it with the supervisor in Producer Regulatory Investigations. My understanding is that if this filing is disapproved, (a) you must stop using all forms right away and possibly cancel the policies you have used these forms with and (b) you cannot submit these forms to the Department again without making the changes required. That will also require new Edition Dates as these will show as "disapproved" when Market Conduct visits your company for an exam.</s><s>[INST]Generate a response to this objection.[/INST]After our initial review of this objection, we requested a call to discuss your objections to this filing, and to obtain clarification as to the specific policy language forming the basis for your objection. We are unclear as to the wording in question which you stated we need to either change or remove. As you indicated in your December 19th note to filer, the Department does not have time to speak with us. In light of this, we made our best attempt to modify our policy language at your request. Please see the marked redlined version for your ease of review. If our marked changes do not meet with your approval or do not satisfy your objection, we ask that you confirm which provision(s) or specific wording in question you have concerns with, and would like changed or removed from the policy? Additionally, if you have an example of acceptable language the Department would prefer that we use in lieu of what we have submitted, that would be helpful as well. Finally, we would like to provide further explanation as to the provisions we have revised. Please note that there is no premium impact for any promotional offers that are not tied to referrals, and we do not sell the policyholders information. Generally, such promotional offers are items such as gift cards, waste bags and holders, pet food coupons, etc. All current policyholders are eligible and receive the same offers. An offer is typically presented when a policyholder reaches a certain milestone (for example, the covered pets birthday). These promotional offers are not contingent upon renewal of the policy. Promotional offers are available on all types of policies. The value of offers might range from a few dollars (e.g., waste bags and holder) to a maximum value of no more than $100. While all policyholders are eligible to receive all offers, the fulfillment of each offer may be based on the achievement of a particular milestone. Using the example from above, that means that all policyholders might be eligible for a $25 gift card on the covered pets 10th birthday but will only receive the $25 gift card if the pet celebrates its 10th birthday, is still covered under the policy, and that promotional offer is still active.</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]I spoke to our Producer Regulatory unit. Here is their determination. 3) We have set discounts based upon the size of the group/strategic partner membership. All groups/strategic partner members of the same size will receive the same discount. Illinois has always required consumers/insureds to all be treated the same. How is the above practice treating all consumers/insureds the same? It's not the consumer/insured's fault they don't belong to the bigger group. Additionally, there are consumer advocacy groups as well as individual consumers who review our filings on a regular basis once they become public access, which this will become after I close it. Therefore, management may look at this filing very closely. I am uploading a copy of the Department's Company Bulletin 2012-112 regarding rebating. It is highly recommended that your company review this. *2) 2) These partners receive financial remuneration in 2 ways: 1. Licensed and appointed agents or agencies can be paid a percentage of premium for referring potential customers. 2. Non-licensed partners can be paid a referral fee in compliance with 215 ILCS 5/500-80. Non-licensed Partners do not sell, solicit or negotiate insurance. Partner customers are directed to the website of Spot. All Partner communications involving pet insurance are reviewed and approved by the carrier. You are correct in stating that these are allowed. What you should be aware of is that you must meet ALL of ILCS 5/500-80. Please look at the following wording from the statute and respond back to me that your company is in compliance and will continue to comply with this statute. If you are in compliance and will continue to comply, please provide an example of what your company will be sending to every consumer who applies for this product. That can be uploaded as a Supporting Documentation. Please note that management and/or Market Conduct may look at this to determine if it meets our requirements. (e) When an insurance producer or business entity charges any fee or compensation separate from commissions deductible from, or directly attributable to, premiums on insurance policies or contracts, it must comply with all of the following: (1) It must provide written disclosure to the consumer or contracting party that clearly specifies the amount or extent of the compensation or fee prior to the delivery of the corresponding policy. A copy of the written disclosure must be maintained by the producer or business entity that collects the compensation or fee for a period of 7 years. (2) If the combined compensation or fee exceeds 10% of a directly attributable premium amount of a corresponding contract or SERFF Tracking #: IAIC-133336736 State Tracking #: Company Tracking #: 2023 INDIVIDUAL PET FORMS - IL State: Illinois Filing Company: Independence American Insurance Company TOI/Sub-TOI: 09.0 Inland Marine/09.0004 Pet Insurance Plans Product Name: 2023 Individual Pet - Forms Project Name/Number: SPOT/NEW PRODUCT FILING-2023 INDIVIDUAL PDF Pipeline for SERFF Tracking Number IAIC-133336736 Generated 03/01/2023 01:12 AM policy, the disclosure must also include the signature of the consumer or contracting party acknowledging the compensation or fee.</s><s>[INST]Generate a response to this objection.[/INST]Thank you for providing additional information which we have reviewed at length. With respect to the discounts, our group and strategic partner discounts are compliant with Illinois law and the above referenced bulletin. The discounts are applied equally to all members of the same class of policyholders. As a result, all policyholders who are members of a specific group/strategic partner will receive the same discount. In addition, all policyholders who are members of a group of a particular size will all receive the same discount. We have reviewed Illinois laws, regulations and guidance. There is no law that requires all policyholders in Illinois to be treated the same. In Accident & Health Insurance, under 215 ILCS 5/364, discrimination between individuals of the same class of risk is prohibited but does not require that every person in Illinois have the same rate. In Medical Professional Liability Insurance, under section 215 ILCS 5/155.18, rates may vary due to expected losses or expenses. The only statute applicable to the pet insurance product that addresses discrimination among policyholders in 215 ILCS 5/424; which only prohibits such discrimination based on race, color, religion or national origin. We respectfully ask that you consider that it is not a violation of law to treat different groups with different attributes differently where that difference can be supported either by expected claims experience or expected expense savings. The reality is that larger groups have smaller acquisition costs on a per insured basis. We want to recognize the savings by passing it on to the members of the group. While not every insured in Illinois is a member of the same sized group, or any group at all, which may affect the amount that person pays for pet insurance; it is not discriminatory to allow for differing discounts based upon group size. If the legislature had intended for there to be no difference in the rates charged to P&C Policyholders, it could have so legislated. We understand that the Insurance Department has discretion and we are not proposing discounts without limitation. We are asking for the ability to provide discounts that recognize expected expense savings. With respect to the referrals, we are in compliance with ILCS 5/500-80. The Producer may pay referral fees to unlicensed entities not conditioned on a sale of insurance. This nominal fee is not separately charged to the customer, therefore, no written disclosure is required. Please note that the carrier does require that any referral partner materials disclose that the partner may receive compensation for making the referral.</s><s>[INST]Generate another objection to this filing.[/INST]I reviewed your 11/11/2022 response to Objection #1 regarding the lack of an Edition Date on the forms submitted. I have had several conversations with our Market Conduct examiners and my manager about Edition Dates over the years. The answer has always been the same. An Edition Date must be on every form so each form can be easily distinguished from the previous ones. It does not matter if it is the first form being submitted or the tenth version of it. We require an Edition Date to be included on the form itself and the Form Schedule. Therefore, my objection stands. Either change the Form Numbers and correct the Form Schedule by adding an Edition Date or withdraw this filing. Until this issue has been corrected, I will not be reviewing any of the forms submitted.</s><s>[INST]Generate a response to this objection.[/INST]At your request, and in light of the additional information you provided, please note that we have revised our form numbers accordingly and have added the edition dates in the Form Schedule in SERFF</s><s>[INST]Generate another objection to this filing.[/INST]I reviewed your 11/11/2022 response to Objection #3 and spoke to someone in our Producer Regulatory unit. We have a few questions that need to be addressed. Remember to be as specific as possible because my management team and our Legal unit may need to review your responses. 1. Who are your "distribution partners" and what types of "underlying contractual agreement" are in place for these? 2. Do your "distribution partners" or "strategic partner" receive any benefit for them recommending your product to their members? Please address this is in depth as your company is bordering on rebating, which is against Illinois statutes. 3. Is every "distribution partner" or "strategic partner" offered the same discount? If they aren't, how does your company determine what the discount amount is? Illinois looks at these types of discounts very closely as all Illinois residents must be treated the same. A discount or incentive cannot be offered to one and not someone else. 4. You stated "the affinity group or the employer agrees to the presentation of the individual pet insurance product to its members or employees for their own purchase." Who is giving this presentation? Is it a licensed agent or broker or someone else? Please remember Illinois has strict guidelines for agents and anyone acting as one.</s><s>[INST]Generate a response to this objection.[/INST]1) Distribution partners are entities with whom Spot has contracted. The underlying contractual agreement is a referral/marketing fee agreement. 2) These partners receive financial remuneration in 2 ways: 1.Licensed and appointed agents or agencies can be paid a percentage of premium for referring potential customers. 2.Non-licensed partners can be paid a referral fee in compliance with 215 ILCS 5/500-80. Non-licensed Partners do not sell, solicit or negotiate insurance. Partner customers are directed to the website of Spot. All Partner communications involving pet insurance are reviewed and approved by the carrier. 3) We have set discounts based upon the size of the group/strategic partner membership. All groups/strategic partner members of the same size will receive the same discount. 4) In the employer market, the sale of the master policy occurs through a licensed broker or agent to the employer or its broker. The employer selects the 1 or 2 group plan designs and those are offered to the employees much like any employer-sponsored benefit plan is offered. All materials that are employee-facing are reviewed and approved by the carrier. The presentation in the context of a non-employer group refers to the method of communication about the availability of pet insurance to the members, which is reviewed and approved by the carrier.</s><s>[INST]Generate another objection to this filing.[/INST]I reviewed your 11/11/2022 response to Objection #4. I understand that the insured can revoke their authorization, but what specific authorizations can they revoke? Is it their decision to not provide you the ability to obtain medical records for your pet? If it is and you've already done your underwriting, how does it affect anything? In that instance, you've already received and SERFF Tracking #: IAIC-133336736 State Tracking #: Company Tracking #: 2023 INDIVIDUAL PET FORMS - IL State: Illinois Filing Company: Independence American Insurance Company TOI/Sub-TOI: 09.0 Inland Marine/09.0004 Pet Insurance Plans Product Name: 2023 Individual Pet - Forms Project Name/Number: SPOT/NEW PRODUCT FILING-2023 INDIVIDUAL PDF Pipeline for SERFF Tracking Number IAIC-133336736 Generated 03/01/2023 01:12 AM reviewed what you needed in order to issue or not issue a policy. What if that's what the consumer does and you haven't completed your underwriting? Do you notify the consumer that you can't issue a policy? If there are other authorizations, how do those affect your decision to issue or not issue a policy. I understand the process of obtaining an app and all the medical records required, having an underwriter review everything to determine whether or not it's a risk that meets your company's guidelines.</s><s>[INST]Generate a response to this objection.[/INST]The insured can revoke any or all of the authorizations listed in the Application Agreement & Authorization section. While some of the authorizations only impact eligibility and initial underwriting and are utilized to determine risk for the purposes of policy issuance, other authorizations also impact policy administration. For example, the policyholders authorization for us to collect payments for premiums subject to their choice of payment, or their authorization for any entity to release records to us at our request, etc. If the policyholder revokes any one of the authorizations during our underwriting process, we will not issue the policy and we will notify the consumer as to the reason why. If they revoke an authorization subsequent to policy issuance, it will specifically depend on which authorization they wish to revoke in order to determine the impact. For example, if they revoke the authorization to provide new or updated medical records, we may not have enough information to determine our liability for a claim, which may result in a claim denial. If the policyholder wishes to withdraw their authorization to collect premiums via a specific payment method, we will request a new payment method to use. When we receive a request to revoke an authorization, we will discuss the specific impact of that decision, if any, with the policyholder. This is a general notice of authorizations, and of the insureds right to revoke their authorizations. The authorization being revoked, as well as the timing of the revocation, will direct any next steps that may occur as a result.</s><s>[INST]Generate another objection to this filing.[/INST]There aren't any Edition Dates on either the forms themselves or the Form Schedule. Each form is required by statute to have an Edition Date that changes with each new version. Does your company change the Form Number and Form Name every time it wants to change the form? 50 Illinois Administrative Code 753.20: a) There must be printed at the head of the policy the name of the insurer or insurers issuing the policy, the location of the Home Office of the insurer or insurers; a statement of whether the insurer is a stock, mutual, reciprocal, Lloyds, alien insurer, or insurer operating under a charter by Special Act of the Legislature of any state. Devices, emblems or designs and dates as are appropriate for the insurer issuing the policy may also be added. b) In a policy in which contingent liability of members or subscribers is provided for, that provision shall be plainly stated in each policy with prominence equal to the indemnifying clause. Any insurer may also print upon the policy such regulations or provisions as may be required by its home state or such as may be appropriate to or required by its form of organization or plan of operation. There may be substituted for the word "company", where it appears in the policy, another term more accurately descriptive of the insurer. c) ALL FORMS MUST BE IDENTIFIED BY A DESCRIPTIVE TITLE, FORM NUMBER AND EDITION IDENTIFICATION. d) All changes from currently filed forms must be highlighted. The preferred format is to underline the new wording and overstrike the deleted or changed language and give an explanation for the changes being made, but alternative methods of indicating changes will also be accepted. Any changes not highlighted will not be deemed filed. e) Typed or printer's proof copies may be submitted for review, but must be refiled in printed form. Statements, provisions or endorsements may not be typed or superimposed on a policy or endorsement. f) All forms must be printed in not less than eight-point type.</s><s>[INST]Generate a response to this objection.[/INST]Thank you for your comments. It is our understanding that Illinois law requires edition identification, but we do not see that such edition identification needs to be incorporated directly into the form number. Since the forms being filed herein for your review and approval are initial filings and are not updates to previously filed forms, they do not include any edition number as part of the form number in the lower left-hand footer. The edition date for the original forms is bracketed in the lower right-hand corner of the forms, and reflect that the initial forms will be new as of 01/2023. In light of our objection, we have removed the brackets so that the edition will always print in Illinois. Additionally, wed like to note when we need to revise these forms, we will submit redlined versions of the form(s) being revised that includes an updated form number to reflect the edition. For example, if we were to modify the Accident and Illness policy form effective 11/2023, we would submit a new policy filing to you with the following form number in the footer, which reflects 11/2023 as the edition date: IAIC-IND-2023-AI-POL-IL_v2023_11. The information in the lower right-hand footer would also change to reflect v.2023.11. Lastly, please note that if we submit an amendatory endorsement to be attached to the policy, instead of updating the policy form directly, we would not update the form number of the policy to reflect an edition date, as the policy number would no longer match the number of the form approved in this filing. The approved form number would stay as approved, and the amendatory endorsement would be attached with its own form number. It is our position that it is acceptable to have a newly approved form without edition identification within the form number, as it is not an edition of a previously approved form. Please let us know if you have any questions or concerns regarding our approach with respect to any of the above example scenarios.</s><s>[INST]Generate another objection to this filing.[/INST]It has come to the Department's attention that we have been allowing exclusionary wording that assumes an insured would act in a fraudulent manner. After management review, it has been decided that we will no longer allow any exclusionary wording that restricts who treats an animal as long as they are accredited and properly licensed in the state of Illinois. Exclusions are allowed for claims that are determined to be fraudulent, but it is inappropriate to assume a specific class of SERFF Tracking #: IAIC-133336736 State Tracking #: Company Tracking #: 2023 INDIVIDUAL PET FORMS - IL State: Illinois Filing Company: Independence American Insurance Company TOI/Sub-TOI: 09.0 Inland Marine/09.0004 Pet Insurance Plans Product Name: 2023 Individual Pet - Forms Project Name/Number: SPOT/NEW PRODUCT FILING-2023 INDIVIDUAL PDF Pipeline for SERFF Tracking Number IAIC-133336736 Generated 03/01/2023 01:12 AM policyholders will act in a fraudulent manner. Moreover, the wording arbitrarily excludes not only current insureds but also other Illinois consumers who might be interested in purchasing animal coverage of any kind. The Departments considers the exclusion to violate 215 ILCS 5/143(2), by containing exceptions and conditions that will unreasonably or deceptively affect the risks that are purported to be assumed by the policy. Therefore, the Department respectfully requests you remove this type of exclusionary wording from every form that includes it and submit it to the Department for compliance review. This applies to all property and casualty lines of business. *I stopped my review of this filing with the application in order to give your company a chance to review all the forms on it for this type of restrictive wording. i am also sending an email directly to the company contact listed on SERFF with this same wording as every form related to any type of animal coverage must be reviewed for compliance with the Department's stance on this type of restrictive wording. Thank you for your cooperation.</s><s>[INST]Generate a response to this objection.[/INST]We have revised our Accident & Illness and Accident Only policies to revise the definition of Veterinarian by removing the exclusionary language. </s><s>[INST]Generate another objection to this filing.[/INST]13. I understand that this agreement and authorizations are required in order to enable IAIC to make eligibility or enrollment determinations relating to my pet(s), or for IAICs underwriting or risk rating determinations. If a refuse to sign, or if I revoke, this agreement and authorization, IAIC may refuse to consider my application for pet insurance. I understand that I may revoke this authorization at any time by notifying IAIC in writing and sending such written notice to IAIC via certified mail. SUCH REVOCATION WILL NOT BE VALID IF IAIC HAS TAKEN ACTION IN RELIANCE UPON THE AUTHORIZATION. (P8) Please explain the wording in all caps. It reads as though the consumer cannot revoke his/her authorization.</s><s>[INST]Generate a response to this objection.[/INST]As stated in the prior sentence, the applicant can revoke their authorization at any time. The sentence in all caps relates to a time period during which we have used a valid authorization that is later revoked. By way of example, suppose we are granted authorization by the insured at the time of enrollment, we then rely on such valid authorization and use it to make an enrollment determination and issue a policy to the insured, and later, the insured revokes use of the authorization. It is our position that we would not be able to use the authorization on any date subsequent to the insureds revocation but stipulate that such revocation of the authorization is only applicable on a go- forward basis and would not apply to the earlier time period during which the authorization was active and used by us.</s>
<s>[INST]<<SYS>>Review this pet insurance filing. Company: AXIS Insurance Company Product: Pet Health State: Illinois Date: 05/03/2023 Description: Filing Description: Under SERFF Tr Num: AXSS-G132998240, an approved filing, the Company submitted a filing which included the form Pet Health Insurance Policy Terms and Conditions, GPTM 050 IL 0520 A. The Company is filing a revised Pet Health Insurance Policy Terms and Conditions, GPTM 050 IL 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 IL 0223 A and all other forms submitted with this filing, if applicable. <</SYS>> Generate an objection to this filing.[/INST] Pages 16 & 17 Cancellation of a policy is not allowed per Illinois simply due to the fact that the consumer did not send in information in respect to a claim Please remove the new additional information the company wishes to add here - "except if any condition in item 6.c. is present6 part c" Pursuant to 215 ILCS 5/143.16a, no policy to which Section 143.11 applies, except for those defined in subsection (a) or (b) of Section 143.13, that has been in effect for 60 days may be cancelled except for one of the following reasons:(a) Nonpayment of premium;(b) The policy was obtained through a material misrepresentation;(c) Any insured violated any of the terms and conditions of the policy; (d) The risk originally accepted has measurably increased; (e) Certification to the Director of the loss of reinsurance by the insurer which provided coverage to the insurer for all or a substantial part of the underlying risk insured; or (f) A determination by the Director that the continuation of the policy could place the insurer in violation of the insurance laws of this State. Thank You.</s><s>[INST]Generate a response to this objection.[/INST]Please see Amendatory Endorsement (Section XVIII) which was filed and approved under SERFF Tr Num AXSS-G132998240 which addresses this issue.</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 State: Illinois Date: 04/18/2023 Description: Filing Description: National Casualty Company (NCC) is submitting for your approval revisions to our existing coverage forms for our VBW-I and VB-II Plans. We recently updated our rates and forms on 2/15/23 and the forms were accidentally marked exempt when they should have been filed with the Department. We apologize for this oversight and would like to submit these forms for your approval at this time. 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. There is no impact to policyholders as coverage or claims processes did not change. <</SYS>> Generate an objection to this filing.[/INST] The Department did advise in our earlier objection that you cannot use the effective dates you requested. April 18, 2023 - the date the filing was received by us - is the earliest of dates the company can use. Would the company care to correct the information shown in the General Information? If so, please provide a Post Submission Update for that also, or include it in your date PSU. Please contact me if you have any questions.</s><s>[INST]Generate a response to this objection.[/INST]We will update the General Information tab and provide a Post Submission Update.</s><s>[INST]Generate another objection to this filing.[/INST]It has come to the Department's attention that we have been allowing exclusionary wording that assumes an insured would act in a fraudulent manner. After management review, it has been decided that we will no longer allow any exclusionary wording that restricts who treats an animal as long as they are accredited and properly licensed in the state of Illinois. Exclusions are allowed for claims that are determined to be fraudulent, but it is inappropriate to assume a specific class of policyholders will act in a fraudulent manner. Moreover, the wording arbitrarily excludes not only current insureds but also other Illinois consumers who might be interested in purchasing animal coverage of any kind. The Departments considers the exclusion to violate 215 ILCS 5/143(2), by containing exceptions and conditions that will unreasonably or deceptively affect the risks that are purported to be assumed by the policy. Therefore, the Department respectfully requests you remove this type of exclusionary wording from every form that includes it and submit it to the Department for compliance review. This applies to all property and casualty lines of business.</s><s>[INST]Generate a response to this objection.[/INST]We are seeking clarification with this objection: Is there specific language on our VBW-I and VB-II coverage forms submitted in this filing that the Department is identifying as exclusionary language or is this objection more of a general one across all of our forms?</s><s>[INST]Generate another objection to this filing.[/INST]Question - was this policy previously a group policy? Just checking - I see that the term is crossed out in the marked copy under the definition of Pet Insurance.</s><s>[INST]Generate a response to this objection.[/INST]Both plans are individual policies that can be purchased through employers. The change in our Pet Insurance definition is to align with the NAIC pet insurance model act.</s><s>[INST]Generate another objection to this filing.[/INST]You have advised in the Benefit provisions that you have changed the dec sheet to show the deductible and annual term limits. Have you provided the Department with a new dec sheet showing these changes. If so, please provide the SERFF tracking number. SERFF Tracking #: NWPP-133641075 State Tracking #: Company Tracking #: VB10304NCCRF State: Illinois Filing Company: National Casualty Company TOI/Sub-TOI: 09.0 Inland Marine/09.0004 Pet Insurance Plans Product Name: Pet Insurance Project Name/Number: 2023-PET-VB10304NCCRF/VB10304NCCRF PDF Pipeline for SERFF Tracking Number NWPP-133641075 Generated 06/08/2023 01:31 AM Thank You.</s><s>[INST]Generate a response to this objection.[/INST]We have changed our contract to provide additional clarification of where a policyholder can view their selected deductible, co-insurance and annual term limits. The dec page is located in SERFF #: SCTT-131547196 for VS-2 (1-18) and then the most recent filing was for an address change to our administration office only under SERFF #: SCTT-132935232 for VS-2 (1-21).</s><s>[INST]Generate another objection to this filing.[/INST]Please be advised the Department cannot allow a new effective date of February 1, 2023 or a renewal effective date of April 12, 2023 for these forms. 50 IL Adm Code 753 states that all filings must be received in SERFF no later than the effective date of use. The earliest a form can be effective is the date the Department receives the form since we are a "File and Use" state. We can allow an effective date of April 18, 2023 for both the new and renewal dates. Please send a Post Submission Update to correct this error. Please contact me if you have any questions. Thank You.</s><s>[INST]Generate a response to this objection.[/INST]Please accept our apologies in reference to any confusion our requested effective dates may have caused. We updated our rates for our VBW-I and VB-II plans on February 15, 2023, which are exempt from filing. We inadvertently marked our forms filing as exempt when they should have been filed with the Department. The forms were also implemented on February 15, 2023. The filing memo provided was uploaded in error and the correct filing memo has been uploaded that references this error. There is no impact to policyholders as coverage or claims processes did not change. We apologize for this oversight and would like to submit these forms for your approval at this time. Additionally, were sending a separate response to your email regarding exclusionary language in our forms.</s>
<s>[INST]<<SYS>>Review this pet insurance filing. Company: XL Specialty Insurance Company Product: Fetch Pet Health Insurance Program 2023 Revision Filing State: Illinois Date: 05/11/2023 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-133082691, a filed/approved filing, the Company submitted a filing which included the form Pet Health Insurance Policy Terms and Conditions, GPTM 050-IL 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-IL 0223 and revised Amendatory Endorsement GPTM 100-IL 0223. The company is primarily adding clarifying language to the forms. The Company has attached in the supporting documentation red-lined copies, and a final clean copy of forms GPTM 050-IL and GPTM 100-IL 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] In addition, we may elect not to renew this policy on the expiration date due to a material change in the condition, factor or loss experience material to insurability. To confirm - is part of this new statement saying that the company may non-renew due to too many losses?</s><s>[INST]Generate a response to this objection.[/INST]Yes, the Company would like to have the option to non-renew due to excessive/adverse loss history. While the Company may non-renew a policy due to losses, the Company will not cancel a policy during the policy term due to losses.</s>
<s>[INST]<<SYS>>Review this pet insurance filing. Company: Trisura Insurance Company Product: Pet Health Insurance State: Illinois 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 Norse 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 rates, rules and forms for use with its new Pet Health Insurance Program. The proposed rates, rules and 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] No where on this application do I see the company name of Trisura Insurance Co. I only see Odie. Is there a way that the customer will be advised of the company they will be doing business with? Perhaps it is under Policy and Terms, but I was not able to click on it. Please confirm. Thank You.</s><s>[INST]Generate a response to this objection.[/INST]Once approved, Trisura will be identified as the carrier for the related states in the footer of the website. The Company would also like to propose an added link to the bottom of the application for clarification. Please see the attached mockups of the screens 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 provide a copy of the application that will be used with this program. An application is required by law in Illinois whether it is online or a paper application. (50 IL Adm Code 753) If you are using an application that has already been filed, please provide the SERFF filing number. Thank You.</s><s>[INST]Generate a response to this objection.[/INST]We have attached a copy of the electronic application.</s><s>[INST]Generate another objection to this filing.[/INST]Page 6 of 22 2 e.i. This adjustment will be based on the changes in your Pets age as well as the overall cost of care. Please advise how the overall cost of care is factored in here. This is not worded well and a lay person may take it to mean that past claims may be taken into effect as well as the age. You specifically stated a premium would not change due to past claims experience. I want to be clear what is included in the calculation here. Thank You.</s><s>[INST]Generate a response to this objection.[/INST]We have revised the wording and have added it to the Amendatory Endorsement, TRSA-OPI-PC113-ILL-SAEN-IL.</s><s>[INST]Generate another objection to this filing.[/INST]Please confirm that Thorson Specialty Insurance Services Pet Health Insurance Program is licensed to do business in the State of Illinois and authorized as an MGA. Thank You.</s><s>[INST]Generate a response to this objection.[/INST]We have submitted a PSU to update Thorson Specialty Insurance Services to Norse Specialty Insurance Services, as there recently was a name change. We do confirm they are authorized to do business in IL as an MGA.</s><s>[INST]Generate another objection to this filing.[/INST]The Department has 2 questions regarding the company using email to contact your insureds. Please answer both. Thank You. The cancellation/nonrenewal language should be amended to explain how notices will be mailed if a party does not give consent or withdrawals consent. SERFF Tracking #: MRTN-133667807 State Tracking #: Company Tracking #: OPI-IL-23001-F State: Illinois Filing Company: Trisura Insurance Company TOI/Sub-TOI: 09.0 Inland Marine/09.0004 Pet Insurance Plans Product Name: Pet Health Insurance Project Name/Number: Pet Health Insurance/OPI-IL-23001-F PDF Pipeline for SERFF Tracking Number MRTN-133667807 Generated 07/14/2023 01:44 AM Please confirm you have done so. --------------------------------------------------------------------- Do you have a form that is used to comply with the regulation below? 215 ILCS 5/143.34 A notice or document may be delivered by electronic means by an insurer to a party under this Section if: (1) the party has affirmatively consented to that method of delivery and has not withdrawn the consent; (2) the party, before giving consent, is provided with a clear and conspicuous statement informing the party of: (A) the right of the party to withdraw consent to have a notice or document delivered by electronic means, at any time, and any conditions or consequences imposed in the event consent is withdrawn; (B) the types of notices and documents to which the party's consent would apply; (C) the right of a party to have a notice or document delivered in paper form; and (D) the procedures a party must follow to withdraw consent to have a notice or document delivered by electronic means and to update the party's electronic mail address; (3) the party: (A) before giving consent, is provided with a statement of the hardware and software requirements for access to, and retention of, a notice or document delivered by electronic means; and (B) consents electronically, or confirms consent electronically, in a manner that reasonably demonstrates that the party can access information in the electronic form that will be used for notices or documents delivered by electronic means as to which the party has given consent. Please provide a copy for the Department review. Thank You.</s><s>[INST]Generate a response to this objection.[/INST]The customer gives consent to our "Electronic Delivery Terms" to receive all notices or documents by electronic means prior to checkout. The Terms state that the insured can email support@odiepetinsurance.com to request paper copies or withdraw consent. We will then mail the document to their last known mailing address on file. A copy of the terms can be found here: https://getodie.com/electronic-delivery-terms/.</s><s>[INST]Generate another objection to this filing.[/INST]Applies To: Entire filing Comment: *Please note that is being sent to every company that offers some kind of coverage for pets/animals. This does not appear to apply to this filing, it is for informational purposes only. It has come to the Department's attention that we have been allowing exclusionary wording that assumes an insured would act in a fraudulent manner. After management review, it has been decided that we will no longer allow any exclusionary wording that restricts who treats an animal as long as they are accredited and properly licensed in the state of Illinois. Exclusions are allowed for claims that are determined to be fraudulent, but it is inappropriate to assume a specific class of policyholders will act in a fraudulent manner. Moreover, the wording arbitrarily excludes not only current insureds but also other Illinois consumers who might be interested in purchasing animal coverage of any kind. The Departments considers the exclusion to violate 215 ILCS 5/143(2), by containing exceptions and conditions that will unreasonably or deceptively affect the risks that are purported to be assumed by the policy. If this would apply to any other pet program, the Department respectfully requests you remove this type of exclusionary wording from every form that includes it and submit it to the Department for compliance review. This applies to all property and casualty lines of business. If you have any questions, please contact this analyst directly. Thank you.</s><s>[INST]Generate a response to this objection.[/INST]Acknowledged </s>
<s>[INST]<<SYS>>Review this pet insurance filing. Company: Independence American Insurance Company Product: PetsBest 2023 New Forms State: Illinois Date: 04/17/2023 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. 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] Senate Bill 1544/215 ILCS 5/408 (1) (jj) The filing fee per company is $50 a form up to a maximum of $1500 per company. The filing fee for an Advisory Organization is $200 per form up to a maximum of $2500. Since you have provided another form, please provide another EFT payment for an additional $50. Thank You.</s><s>[INST]Generate a response to this objection.[/INST]My apologies for the oversight. This additional $50 is being added.</s><s>[INST]Generate another objection to this filing.[/INST]Page 2 of 21 insured/spouse/partner 750 ILCS 75/1: The form must be revised to include a civil union in any definition or use of the terms "spouse," "family," "married," "immediate family," "dependent," or any other term descriptive of spousal relationships as those terms are used throughout Illinois law.</s><s>[INST]Generate a response to this objection.[/INST]Please see the attached Amendatory Endorsement. We have revised this provision to reference Pet Owner.</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 Department does not have a Scottsdale, AZ address on file for you. Is this a recent change? Please advise and if necessary make an address change with our Financial Corporate Regulatory Unit. You will need to contact Mary Savage. You can reach her at marcy.savage@illinois.gov or at (217) 524-0016 Thank you.</s><s>[INST]Generate a response to this objection.[/INST]Thank you for your comments. Our office did send the NAIC address change form to all states in August. We have contacted Mary Savage and resubmitted this information.</s><s>[INST]Generate another objection to this filing.[/INST]Page 6 of 15 Exclusion #13 No coverage is provided for Veterinarian Expenses when the Veterinarian is the policyholder Our records show that the Department advised your company that we no longer had any restrictions on a Veterinary Provider performing services on his/her own pet. You acknowledge this in November of 2022. Due to the fact the STate of Illinois no longer restricts veterinarians from treating their own pets, will the company reconsider their rule regarding the payment of their own claims? SERFF Tracking #: IAIC-133640433 State Tracking #: Company Tracking #: PETSBEST 2023 NEW FORMS - IL State: Illinois Filing Company: Independence American Insurance Company TOI/Sub-TOI: 09.0 Inland Marine/09.0004 Pet Insurance Plans Product Name: PetsBest 2023 New Forms Project Name/Number: PetsBest/2023 Forms PDF Pipeline for SERFF Tracking Number IAIC-133640433 Generated 08/04/2023 01:08 AM Thank You.</s><s>[INST]Generate a response to this objection.[/INST]This was an oversight. We have removed the exclusion from both policies via the Amendatory Endorsement.</s><s>[INST]Generate another objection to this filing.[/INST]Page 7 D Factors that could impact coverage: 4. This policy is not an excess policy. "Other Insurance" provisions must state that coverage under the policy will share proportionately with other similar coverages the insured may have. Any forms that contain provisions to the contrary are deemed to contain exceptions and conditions that unreasonably or deceptively affect the risks that are purported to be assumed by the policy, in violation of Section 143(2) and will be disapproved accordingly.</s><s>[INST]Generate a response to this objection.[/INST]Please see the attached Amendatory Endorsement. We have revised this provision for both policies to share equally payment of loss.</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]Page 7 A. Submitting a claim. For the fastest and easiest claim fi ling experience Could you bring the word filing together and remove that space? We would appreciate it. :) Thank You.</s><s>[INST]Generate a response to this objection.[/INST]We have uploaded a corrected policy to make this typo change. We also discovered .com was missing in our URL for submitting a claim. (This specific error was discovered in both policies). Section 6 has also been corrected to remove office visits and examinations as it is our intention to cover these items on an accident only policy.</s><s>[INST]Generate another objection to this filing.[/INST]The rewards program must be included as a rule in your manual. The rule must be updated every time there is a change in the program. The rule should explain the details of the program including but not limited to the following information; The name of the independent third party if applicable and name(s) of all participating vendors. Details regarding how policyholders earn points and how they may be redeemed. A list of the specific rewards that are available. Longevity of earned points, i.e. if they expire after a certain time or upon policy termination.</s><s>[INST]Generate a response to this objection.[/INST]We have removed the De Minimus Gifts provision from our policy forms via the Amendatory Endorsement.</s><s>[INST]Generate another objection to this filing.[/INST]De minimis gifts - Regarding the gift information noted in the policy, please provide more information to show you are in compliance with 215 ILCS 5/151. The name of the independent third party if applicable and name(s) of all participating vendors. Details regarding how policyholders earn points and how they may be redeemed. A list of the specific rewards that are available. Longevity of earned points, i.e. if they expire after a certain time or upon policy termination. Thank You.</s><s>[INST]Generate a response to this objection.[/INST]Please see our response to objection #7. We have removed the De Minimus Gifts provision from our policy forms via the Amendatory Endorsement.</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]Page 9 of 21 Exclusion s. Electromagnetic exclusions are prohibited. Any forms that contain provisions to the contrary are deemed to contain exceptions and conditions that unreasonably or deceptively affect the risks that are purported to be assumed by the policy, in violation of Section 143(2) and will be disapproved accordingly.</s><s>[INST]Generate a response to this objection.[/INST]We have revised the exclusion from both policies via the Amendatory Endorsement.</s><s>[INST]Generate another objection to this filing.[/INST]Page 10 of 21 B Factors that could impact Coverage 5 Excess insurance limitation "Other Insurance" provisions must state that coverage under the policy will share proportionately with other similar coverages the insured may have. Any forms that contain provisions to the contrary are deemed to contain exceptions and conditions that unreasonably or deceptively affect the risks that are purported to be assumed by the policy, in violation of Section 143(2) and will be disapproved accordingly.</s><s>[INST]Generate a response to this objection.[/INST]Please see the attached Amendatory Endorsement. We have revised this provision for both policies to share equally payment of loss.</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]Page 11 of 21 B Factors that could impact coverage 8 ....If any policyholder provides false, misleading, and/or dishonest information, we may not pay the claim, may void that policy,and may be required by law to report it to governmental authorities. 215 ILCS 5/154: No personal lines policy may be rescinded after the policy has been in effect for one year, or one policy period, whichever is less. SERFF Tracking #: IAIC-133640433 State Tracking #: Company Tracking #: PETSBEST 2023 NEW FORMS - IL State: Illinois Filing Company: Independence American Insurance Company TOI/Sub-TOI: 09.0 Inland Marine/09.0004 Pet Insurance Plans Product Name: PetsBest 2023 New Forms Project Name/Number: PetsBest/2023 Forms PDF Pipeline for SERFF Tracking Number IAIC-133640433 Generated 08/04/2023 01:08 AM</s><s>[INST]Generate a response to this objection.[/INST]Please see the attached Amendatory Endorsement. We have revised this provision for both policies to replace void with cancel</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]Will this policy have any non-renewal provisions?</s><s>[INST]Generate a response to this objection.[/INST]We have added a non-renewal provision for both policies via our Amendatory Endorsement to comply with 215 ILCS 5/143.17.</s>
<s>[INST]<<SYS>>Review this pet insurance filing. Company: American Pet Insurance Company Product: Trupanion Pet Health Insurance State: Indiana Date: 10/20/2022 Description: Filing Description: Effective Date: 12/1/2022 Overall Rate Impact: +8.0% Base Rates: Revising based on experience and in consideration of other proposed changes Recovery and Complementary Care (RACC) Rider Factors: Revising based on experience <</SYS>> Generate an objection to this filing.[/INST] Good afternoon The Indiana Department of Insurance has received a confidential filing request for 1 company. In this case, the required fee for the confidential treatment filing is $100. A balance of $100 remains due. For reference, the Indiana Code 27-1-3-15 establishes requirements for Rate and Form submissions and per 760 IAC 1-80-2(c)(4) reflects confidential guidelines. Please do not hesitate to contact me should you have any questions. Thank you, Kristi Ware P: (317) 232-0688 KWare@idoi.IN.gov</s><s>[INST]Generate a response to this objection.[/INST]We believe this objection has been resolved through filing notes. Please let us know if anything else is needed. Thank you.</s>
<s>[INST]<<SYS>>Review this pet insurance filing. Company: Independence American Insurance Company Product: 2023 Individual Pet State: Indiana Date: 09/09/2022 Description: Filing Description: SERFF Tracking #: IAIC-133331886 State Tracking #: EFT OK / Company Tracking #: 2023 INDIVIDUAL PET - IN State: Indiana Filing Company: Independence American Insurance Company TOI/Sub-TOI: 09.0 Inland Marine/09.0004 Pet Insurance Plans Product Name: 2023 Individual Pet Project Name/Number: SPOT/NEW PRODUCT FILING-2023 INDIVIDUAL PDF Pipeline for SERFF Tracking Number IAIC-133331886 Generated 11/16/2022 01:59 A <</SYS>> Generate an objection to this filing.[/INST] Objection 2 Applies To: IAIC-IND-2023-AI-POL-LV-IN, [No date], Policy/Coverage Form, Accident and Illness Pet Insurance Policy (Form) IAIC-IND-2023-A-POL-LV-IN, [No date], Policy/Coverage Form, Accident Pet Insurance Policy (Form) Comment: Premium Discounts Promotional Items Partner Promotional Items Prizes, Contests, Sweepstakes, or Raffles Special Promotions for Referrals Special Promotions for Partner Referrals Value-Added Services Partner Value-Added Services Non-Insurance Services Partner Non-Insurance Services Descriptions of products and services permitted under IC 27-1-47-2 are not required to be filed with the Indiana Department of Insurance and should not be included in policy contract forms. Please remove the above referenced items from the above referenced forms. Response 2: Thank you for your comment. We have reviewed the citation noted as well as other Indiana insurance statutes and regulations, and despite our best efforts, we are unable to locate a requirement with force of law that would prohibit a carrier from incorporating provisions into our policy, regardless of whether state law requires filing of such information. In addition, it is IAICs understanding that to ensure compliance with IC 27-1-20-30, the above cited provisions must be contained in the filed policy form.As we desire to provide full transparency to our Indiana policyholders with respect to our offerings, we respectfully request that you withdraw your SERFF Tracking #: IAIC-133331886 State Tracking #: EFT OK / Company Tracking #: 2023 INDIVIDUAL PET - IN State: Indiana Filing Company: Independence American Insurance Company TOI/Sub-TOI: 09.0 Inland Marine/09.0004 Pet Insurance Plans Product Name: 2023 Individual Pet Project Name/Number: SPOT/NEW PRODUCT FILING-2023 INDIVIDUAL PDF Pipeline for SERFF Tracking Number IAIC-133331886 Generated 11/16/2022 01:59 AM objection in this regard. This is being referred to Senior Management.</s><s>[INST]Generate a response to this objection.[/INST]As indicated in our October 12th response and noted in your objection above, we are unable to locate a requirement with force of law that would prohibit us from incorporating provisions into our policy form, regardless of whether state law requires filing of such information, in an attempt to provide full transparency to policyholders. That being said, in light of your second objection in this regard, in a good faith effort to get this filing approved, we have removed the following provisions from our policy form: Premium Discounts, Promotional Items, Partner Promotional Items, Prizes, Contests, Sweepstakes, or Raffles, Special Promotions for Referrals, Special Promotions for Partner Referrals, Value-Added Services, Partner Value-Added Services, Non-Insurance Services, and Partner Non-Insurance Services. Based on the Departments objection, it is our understanding that the Departments position is that despite the requirements set forth in IC 27-1-20-30, the filed policy form contract does not need to contain the above referenced provisions in order for IAIC or the applicable producer to provide said promotional items, premium discounts, special promotions for referrals, etc.; and to that end, removal of the above provisions from our policy form at your request will not prohibit us from providing such offerings in your state. If our understanding of your position on this objection is incorrect, please let us know.</s><s>[INST]Generate another objection to this filing.[/INST]Thank You for the explanation. How is the insured educated regarding the information? Phone counseling, sales counseling?</s><s>[INST]Generate a response to this objection.[/INST]There are several ways in which a consumer is provided with information about this optional rider. Since the majority of sales are direct to consumer information is provided on the website both informationally throughout the site and in some FAQs. Additionally, the website provides a phone number for consumers to call if they have any additional questions. For consumers that obtain coverage through an agent/broker, all agents are provided with training on the different coverages and receive monthly follow- up training. In addition, marketing materials (including both digital and print media) are provided to agents working directly with consumers.</s><s>[INST]Generate another objection to this filing.[/INST]Thank You for the explanation. How is the insured educated regarding the information? Phone counseling, sales counseling?</s><s>[INST]Generate a response to this objection.[/INST]Since the sales and marketing will be handled the same for the optional coverage riders, please see our response for objection 1.</s><s>[INST]Generate another objection to this filing.[/INST]Legal Action The insured has two years to bring suite in the State of Indiana. IC 27-1-13-17</s><s>[INST]Generate a response to this objection.[/INST]Thank you for your comment bringing this to our attention. We have revised our legal action provision accordingly. Please see the attached marked redlined version for your ease in review.</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]Premium Discounts Promotional Items Partner Promotional Items Prizes, Contests, Sweepstakes, or Raffles Special Promotions for Referrals Special Promotions for Partner Referrals Value-Added Services Partner Value-Added Services Non-Insurance Services Partner Non-Insurance Services Descriptions of products and services permitted under IC 27-1-47-2 are not required to be filed with the Indiana Department of Insurance and should not be included in policy contract forms. Please remove the above referenced items from the above referenced forms.</s><s>[INST]Generate a response to this objection.[/INST]Thank you for your comment. We have reviewed the citation noted as well as other Indiana insurance statutes and regulations, and despite our best efforts, we are unable to locate a requirement with force of law that would prohibit a carrier from incorporating provisions into our policy, regardless of whether state law requires filing of such information. In addition, it is IAICs understanding that to ensure compliance with IC 27-1-20-30, the above cited provisions must be contained in the filed policy form.As we desire to provide full transparency to our Indiana policyholders with respect to our offerings, we respectfully request that you withdraw your objection in this regard.</s><s>[INST]Generate another objection to this filing.[/INST]Cancer Treatment Indemnity Benefit Coverage Changes: You may cancel this Rider at any time. If You cancel this Rider, the Covered Pet cannot be re-enrolled or receive Cancer Treatment Indemnity benefits at any future time. You have this in a few spots in this endorsement and others? You are not giving access to the insured for any coverage they drop? Why? Please explain?</s><s>[INST]Generate a response to this objection.[/INST]Thank you for your comment. This is very similar to our response above. We only allow a policyholder to elect coverage of the Cancer Treatment Indemnity Benefit Rider at the time of the pets initial enrollment into the Policy. The intent is that we accept premium payment in exchange for our promise to pay in the event of a cancer diagnosis. The incidence of cancer increases as pets age. If we were to allow policyholders to elect the benefit at any time, they could effectively postpone paying premium until a time when benefits are more likely to be needed, resulting in greater adverse selection and potential risk of fraud or material misrepresentation.</s><s>[INST]Generate another objection to this filing.[/INST]IC 27-4-1-5.6Every insurer must provide to policyholders a one-time written notice of opportunity to file a complaint with the Indiana Department of Insurance. See Bulletin 128 for sample notice.</s><s>[INST]Generate a response to this objection.[/INST]Upon review of your comment, we have added a Claims Questions provision to the CLAIM CONDITIONS provision to confirm our compliance with the states requirement. Please see the marked redlined version attached for your ease of review.</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]You have more than one Pet Insurance Program on file in the State of Indiana? Are you closing business under your old program? Do current insured have access to this new program. They need to be told that there is a new program and they can switch to the new program. The old program would need to be closed or stay in run off until it closes. Please explain and provide additional information.</s><s>[INST]Generate a response to this objection.[/INST]This product filing is for new business and is not intended to replace any forms or rates currently on file and approved by your Department. We do not intend to close any current block of business, and this product will be marketed concurrently with other products underwritten by Independence American Insurance Company. Upon your approval and our implementation of this product, any individual seeking to obtain pet insurance may apply for this coverage, including any persons with existing pet insurance policies, regardless of whether such coverage is underwritten by Independence American Insurance Company or another carrier. If you have any questions or concerns, please let us know. We would welcome the opportunity to discuss this product offering and to address any remaining questions you might have. </s>
<s>[INST]<<SYS>>Review this pet insurance filing. Company: American Pet Insurance Company Product: Trupanion State: Indiana Date: 09/09/2022 Description: Filing Description: American Pet Insurance Company (“APIC”) is submitting this form filing to introduce a new pet health insurance plan for all newly enrolled pets. All currently enrolled pets will remain on the approved Trupanion pet health plan. The Explanatory Memorandum attached to the Supporting Documentation tab highlights the key differences between this new plan and the existing plan. <</SYS>> Generate an objection to this filing.[/INST] You state American Pet Insurance Company (APIC) is submitting this form filing to introduce a new pet health insurance plan for all newly enrolled pets. All currently enrolled pets will remain on the approved Trupanion pet health plan. But will the old program be closed to new members? You can not have two programs running at the same time. I tried calling but was unable to reach anyone with the information we have one file.</s><s>[INST]Generate a response to this objection.[/INST]We appreciate that you tried to reach us via phone prior to sending your objection and apologize that you were unable to reach someone. Justin Compton can generally be reached at (888) 738-7478 ext 3948. There is only one Trupanion program. Upon approval, this policy version (V01.202206) will be active for new enrollments, while members that enrolled on the current policy will remain on that version (V10.201902). Thank you.</s><s>[INST]Generate another objection to this filing.[/INST]Im sorry this seems to have created another questions? The essence of this program is not changing; APIC offers a 30 day self-terminating insurance policy that is available only for pets who have had a physical exam within 24 hours prior to policy issuance. The rate/rule filing (forthcoming) provides additional details on how this program works. Is that this program or a new program. Im sorry that was very confusing? Each program will need to be filled seperatly.</s><s>[INST]Generate a response to this objection.[/INST]APIC is filing for one Pet Health Insurance Plan; in other words, it is just one program. As part of this program, there is an endorsement and distinct declaration page for policyholders that enroll within 24 hours from obtaining a veterinary exam, as the deferral period is waived for pets that have just had an examination. APIC had previously filed and was approved for such an endorsement and accompanying declaration page with its previous pet health insurance program (APII-129838759). If it would be easier to discuss, we are happy to set up some time that works best for the Department.</s><s>[INST]Generate another objection to this filing.[/INST]Further, Trupanion developed and patented software that allows Trupanion to integrate with a veterinarians computer systems to pay claims to the hospital directly at the time of checkout, eliminating the need for a cumbersome reimbursement process. You state you are integrating your software into the veterinarians office system for claims purposes? Will the software be used solely for claims payment or is there a possibility you would later use it for sales? This would be prohibited as the selling of insurance products by unlicensed individuals is not allowed.</s><s>[INST]Generate a response to this objection.[/INST]Please see "Responses to Objections Received September 12, 2022" attached to 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]No. Because the coverage is different (most notably the difference between a policy whereby certain policyholders have satisfied their per condition deductibles), pets on the current policy will remain on that policy until they choose to terminate coverage. You cannot have two programs running simultaneously side by side. All insureds need to have access to the new program. Meaning that current insureds in the old program need to be able to switch to the new program if they so desire after being notified of the new program from you. This would traditionally happen at renewal along with any possible switch in programs. Are you closing the old book and leaving the old policies until they either run out of cancel. Please explain but the current insured needs to have access to the new program if they so chose. You will also need to explain that a new pet that is added will go on the new policy if the insured choses to stay with the old policy. This may have been approved in Florida as it was submitted but just because something is approved in one state does not mean that it will be approved without changes and other items in another state.</s><s>[INST]Generate a response to this objection.[/INST]Please see "Responses to Objections Received September 12, 2022" attached to 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]If a pet is over the age of one, and enrolls without a veterinary exam, we will attempt to contact the member to inform them of the veterinary exam requirement. If the pet owner does not provide proof of a veterinary exam, we may cancel the policy and refund their premium and their enrollment fee, but not the Medical Records Summary fee. How will the insured be notified and educated that this in required? Meaning that they need as veterinary exam. The insured needs to be given a fair chance to gain coverage with no hindrances. Also asked prior will the office staff be selling insurance products?</s><s>[INST]Generate a response to this objection.[/INST]Please see "Responses to Objections Received September 12, 2022" attached to 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]Why do you have three Declarations each labeled something different. I did not see a reference to After Enrollment or Certificate Program. Please explain why you have three different declarations and what they apply to as that information is not in SERFF Tracking #: APII-133388531 State Tracking #: EFT OK / Company Tracking #: APIC-TRUC-IN202206-F State: Indiana Filing Company: American Pet Insurance Company TOI/Sub-TOI: 09.0 Inland Marine/09.0004 Pet Insurance Plans Product Name: Trupanion Project Name/Number: / PDF Pipeline for SERFF Tracking Number APII-133388531 Generated 03/03/2023 03:35 AM the policy. If these are something the insured is going to be issued then you need to provide information to them regarding those items.</s><s>[INST]Generate a response to this objection.[/INST]Please see "Responses to Objections Received September 12, 2022" attached to 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]<<SYS>>Review this pet insurance filing. Company: Cimarron Insurance Company, Inc. Product: Pet Insurance Program State: Indiana Date: 11/22/2022 Description: Filing Description: Cimarron Insurance Company, Inc. (“Company”) respectfully submits this initial filing for forms, rates, rules and rating factors for a new Pet Health Insurance Program. This program does not replace any forms, 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. <</SYS>> Generate an objection to this filing.[/INST] Bulletin 106 For policies and forms subject to Ind. Code 27-1-26, pursuant to Ind. Code §27-1-26-4, the insurer issuing the non-English language policy must also certify that if translated into English, the policy would comply with Ind. Code §27-1-26-3.</s><s>[INST]Generate a response to this objection.[/INST]My apologies - attached is the certification.</s><s>[INST]Generate another objection to this filing.[/INST]XIII. DISCOUNTS Marketing Partner 10% What are your Marketing Partners? What Process does this go through?</s><s>[INST]Generate a response to this objection.[/INST]Kanguro has three main distribution channels. We sell Direct-to-Consumer via www.kanguroinsurance.com, we partner up with agency networks/agents and pay them a commission for selling the product, and we partner up with affinity partners (employee networks, pet industry participants, and others). Our marketing partners can potentially offer customers a 10% discount to promote the product and pet health.</s><s>[INST]Generate another objection to this filing.[/INST]ENROLLMENT FEE Can you explain this and the process that arrived at $25 and $15?</s><s>[INST]Generate a response to this objection.[/INST]A $25.00 administration fee is charged to policyholders when enrolling a first pet. This is in line with the vast majority of industry participants. This fee is designed to cover a portion of administrative expenses such as but not limited to the efforts of collecting medical records, 24/7 vet advice, click-to-chat communication, and technology expenses (Kanguro super APP). In the event of a flat cancel inside the waiting period, the fee will be fully reimbursed. In the event of partial cancellation, no amount of this fee will be refunded. The $15.00 administration fee charged to existing customers at renewal (also in line with industry participants) helps cover the cost of re-underwriting clients and policy issuance expenses.</s><s>[INST]Generate another objection to this filing.[/INST]INSTALLMENT FEE Can you explain this and the process that arrived at the fee?</s><s>[INST]Generate a response to this objection.[/INST]A $12.00 installment fee ($1.00/month) is charged upfront to customers that elect to pay for the policy on a monthly basis (annual pay customers are not subject to the fee). The fee only partially covers the credit card and bill processing fees (12 different transactions).</s>
<s>[INST]<<SYS>>Review this pet insurance filing. Company: AXIS Insurance Company Product: Pet Health State: Indiana Date: 03/23/2023 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] The Department analyst indicated the filing was re-opened. In this case, the required fee for the re-opening is $35 per filing. Any subsequent changes to the filing after completion of the review may generate additional filing fees. Indiana is a retaliatory state with regard to filing fees and requires the greater of the insurer's domicile fee or the Indiana fee. A balance of $35 remains due. For reference, the Indiana Code 27-1-3-15 establishes requirements for Rate and Form submissions and Indiana Code 27-1-20-12 reflects retaliatory guidelines. Please do not hesitate to contact me should you have any questions. We appreciate your help with this request. Thank you, Kristi Ware P: (317) 232-0688 KWare@idoi.IN.gov</s><s>[INST]Generate a response to this objection.[/INST]The fee has been sent via EFT.</s>
<s>[INST]<<SYS>>Review this pet insurance filing. Company: AXIS Insurance Company Product: Pet Health State: Indiana Date: 04/07/2023 Description: Filing Description: SERFF Tracking #: AXSS-G133613290 State Tracking #: EFT OK / Company Tracking #: FETCH-2023-03-0022-IN State: Indiana 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-G133613290 Generated 05/26/2023 02:12 A <</SYS>> Generate an objection to this filing.[/INST] The Department analyst indicated the filing was re-opened. In this case, the required fee for the re-opening is $35 per filing. Any subsequent changes to the filing after completion of the review may generate additional filing fees. Indiana is a retaliatory state with regard to filing fees and requires the greater of the insurer's domicile fee or the Indiana fee. A balance of $35 remains due. For reference, the Indiana Code 27-1-3-15 establishes requirements for Rate and Form submissions and Indiana Code 27-1-20-12 reflects retaliatory guidelines. Please do not hesitate to contact me should you have any questions. We appreciate your help with this request. Thank you, Kristi Ware P: (317) 232-0688 KWare@idoi.IN.gov</s><s>[INST]Generate a response to this objection.[/INST]Additional filing fees have been submitted. Thank you for your help.</s><s>[INST]Generate another objection to this filing.[/INST]The Department analyst indicated the filing was re-opened. In this case, the required fee for the re-opening is $35 per filing. Any subsequent changes to the filing after completion of the review may generate additional filing fees. Indiana is a retaliatory state with regard to filing fees and requires the greater of the insurer's domicile fee or the Indiana fee. A balance of $35 remains due. For reference, the Indiana Code 27-1-3-15 establishes requirements for Rate and Form submissions and Indiana Code 27-1-20-12 reflects retaliatory guidelines. Please do not hesitate to contact me should you have any questions. We appreciate your help with this request. Thank you, Kristi Ware P: (317) 232-0688 KWare@idoi.IN.gov</s><s>[INST]Generate a response to this objection.[/INST]Additional fees have been submitted via EFT.</s>
<s>[INST]<<SYS>>Review this pet insurance filing. Company: Independence American Insurance Company Product: 2023 VERSION 4 State: Indiana Date: 04/11/2023 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] Who are your strategic partners?</s><s>[INST]Generate a response to this objection.[/INST]The partners are PetPace, Liberty Mutual, Helmsman Insurance Agency, BBVA Compass, Subaru, SafeCo, AOL, Assurant, BBVA, Travelers Insurance, Travelers, Volvo, The General, and Purina Consumers.</s><s>[INST]Generate another objection to this filing.[/INST]Strategic Partner Discount Who are your strategic partners and why are you giving them a 10% discount?</s><s>[INST]Generate a response to this objection.[/INST]Strategic partners are provided with a discount to reflect an expected reduction in acquisition costs on a per pet basis due to increased scale.</s>
<s>[INST]<<SYS>>Review this pet insurance filing. Company: AXIS Insurance Company Product: Pet Health State: Indiana Date: 04/12/2023 Description: Filing Description: Under SERFF Tr Num: AXSS-G132998241, 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] The Department analyst indicated the filing was re-opened. In this case, the required fee for the re-opening is $35 per filing. Any subsequent changes to the filing after completion of the review may generate additional filing fees. Indiana is a retaliatory state with regard to filing fees and requires the greater of the insurer's domicile fee or the Indiana fee. A balance of $35 remains due. For reference, the Indiana Code 27-1-3-15 establishes requirements for Rate and Form submissions and Indiana Code 27-1-20-12 reflects retaliatory guidelines. Please do not hesitate to contact me should you have any questions. We appreciate your help with this request. Thank you, Kristi Ware P: (317) 232-0688 KWare@idoi.IN.gov</s><s>[INST]Generate a response to this objection.[/INST]I submitted the $35 fee when I submitted revised effective dates, 6/5/23.</s>
<s>[INST]<<SYS>>Review this pet insurance filing. Company: Liberty Insurance Underwriters Inc. Product: Pet Insurance State: Kansas Date: 10/17/2022 Description: Filing Description: This filing serves to revise the 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] Please provide actuarial support for the development of the proposed premium rates.</s><s>[INST]Generate a response to this objection.[/INST]As per the request we are providing rate/rule manual and Kansas state exception page. Our apologies for not submitting the rate documents. In the initial filing (</s><s>[INST]Generate another objection to this filing.[/INST]Please provide rates.</s><s>[INST]Generate a response to this objection.[/INST]Changes proposed to coverage in this filing have negligible impact on rates/premiums. The addition of age factors in the rate manual may increase the premium, depending on the age of the pet.</s>
<s>[INST]<<SYS>>Review this pet insurance filing. Company: United States Fire Insurance Company Product: PET - V4.5 State: Kansas Date: 11/16/2022 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 associated module; this form was originally approved under CRUM-131553271 and withdrawn in CRUM-132962335. There are no changes to the originally approved form aside from edition date. <</SYS>> Generate an objection to this filing.[/INST] Does this have a corresponding rule that needs to be filed? Will this endorsement be attached to all new and existing policies?</s><s>[INST]Generate a response to this objection.[/INST]There is not a corresponding rule filing as the SubTOI is exempt. This will be an optional form for future use.</s><s>[INST]Generate another objection to this filing.[/INST]Where is the rate manual with this Table 2.7.5 with the corresponding rating factor to discount the current rates being proposed with this filing? We do no see it anywhere in this filing?</s><s>[INST]Generate a response to this objection.[/INST]Per CRUM-132160156 we were instructed Pet insurance rates/rules are not required to be filed pursuant to K.A.R. 40-3-24. Consequently the rate/rule manual was not included with this filing. However it has been added to the Supporting Documentation tab.</s><s>[INST]Generate another objection to this filing.[/INST]Please advise if the current rates contemplate the coverage which would be excluded by the proposed endorsement. Such explanation is necessary as a restriction of coverage is tantamount to a rate increase which may result in an excessive premium rate level unless a corresponding rate decrease is filed, pursuant to KSA 40-954.</s><s>[INST]Generate a response to this objection.[/INST]The current rates contemplate the coverage which would be excluded by the proposed endorsement. A corresponding rating factor to discount the current rates is being proposed, which can be found in Table 2.7.5 of the rate manual.</s>
<s>[INST]<<SYS>>Review this pet insurance filing. Company: Cimarron Insurance Company, Inc. Product: Pet Insurance Program State: Kansas Date: 12/05/2022 Description: Filing Description: Cimarron Insurance Company, Inc. (“Company”) respectfully submits this initial filing for forms, rates, rules and rating factors for a new Pet Health Insurance Program. This program does not replace any forms, 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. <</SYS>> Generate an objection to this filing.[/INST] Thank you for your previous responses, however upon review of the amendatory, it does not appear the in app purchase are specifically addressed. Please confirm if any in app purchase are made and canceled they will be refunded pro rata as well.</s><s>[INST]Generate a response to this objection.[/INST]Please refer to the attached updated amendatory. We hereby confirm that if any in application purchases are made and cancelled, they will be refunded pro rata as well.</s><s>[INST]Generate another objection to this filing.[/INST]As the terms and conditions are part of the application please move the terms and conditions to the forms tab for review/approval.</s><s>[INST]Generate a response to this objection.[/INST]My apologies - we have done so.</s><s>[INST]Generate another objection to this filing.[/INST]Regarding the section In-app Purchases: The filing does not appear to comply with the provisions of K.A.R. 40-3- 15 and K.S.A. 40-2,120 through K.S.A. 40-2,122 with regard to cancellation and nonrenewal. Please amend the filing to comply.</s><s>[INST]Generate a response to this objection.[/INST]Please refer to the attached updated amendatory which addresses your concerns.</s><s>[INST]Generate another objection to this filing.[/INST]Please advise if insureds who wish to conduct business in paper form will also be eligible for Promotions.</s><s>[INST]Generate a response to this objection.[/INST]We hereby confirm that insureds who conduct business in paper format are indeed eligible for promotions.</s><s>[INST]Generate another objection to this filing.[/INST]Regarding the section Termination: This filing does not comply with K.S.A. 40-2,120 and K.A.R. 40-3-15. The policy may only be cancelled for the specific reasons listed in the statute. Please make the necessary revisions.</s><s>[INST]Generate a response to this objection.[/INST]Please refer to the attached updated amendatory which addresses your concerns.</s><s>[INST]Generate another objection to this filing.[/INST]Regarding the section Changes to These Terms and Conditions: Please be advised as the terms and conditions are part of the application they must be submitted to the DOI for review/approval prior to being sent to the insured.</s><s>[INST]Generate a response to this objection.[/INST]Understood; the Company will comply. </s><s>[INST]Generate another objection to this filing.[/INST]Regarding page four: Please provide the terms and conditions the insured must agree to.</s><s>[INST]Generate a response to this objection.[/INST]Attached is the information you requested.</s><s>[INST]Generate another objection to this filing.[/INST]Please submit the application under the forms tab for review and approval.</s><s>[INST]Generate a response to this objection.[/INST]We have moved the application screenshots to the form schedule.</s><s>[INST]Generate another objection to this filing.[/INST]As previously stated, In reviewing the forms, we find multiple brackets to signify variable language. Please provide this department with an exhibit of all possible variables used in the brackets. This appears necessary to avoid a potential violation of K.S.A. 40-216. The Statement of Variability will need to clearly state all possible values that will be placed in all occurrences of brackets. As noted previously the john doe version of the declarations is sufficient for the declarations in this regard.</s><s>[INST]Generate a response to this objection.[/INST]Please refer to the attached Statement of Variability.</s><s>[INST]Generate another objection to this filing.[/INST]As previously stated, Pursuant to K.S.A. 40-216, insurance companies must file all forms utilized in the transaction of business in Kansas. K.A.R. 40-3-5 further requires that, regardless of bureau affiliation, all basic policy forms and jackets must be filed for review and approval. Please submit the following additional forms: policy jackets application (if attached to the policy or if it will bind coverage), notice of cancellation and nonrenewal for Kansas or equivalent, certificate of insurance (K.S.A. 40-955), insurance identification card (K.S.A. 40-3104)</s><s>[INST]Generate a response to this objection.[/INST]Please refer to the Company's cancellation and nonrenewal notices, as well as screen shots of its application form/process. The Company does not use policy jackets or certificates of insurance/ID cards.</s><s>[INST]Generate another objection to this filing.[/INST]As previously stated, K.S.A. 16-1605(b), K.S.A. 40-5802, K.S.A. 40-5804(c)(1) and K.S.A. 40-5804(c)(2)(B) establishes the Electronic Notice and Document Act which allows the use of electronic means for sending insurance notices and documents. In order to send electronic notices and documents to another party, the insurer must obtain the consent of the insured. Additionally, an insured who has opted in should have a mechanism to opt out if so desired. Please amend the filing to comply with these statutes. Please amend to advise how the insured would change a selection once the policy is in place. It is noted you have advised how the company would change the selections, please advise how the insured would change the selection.</s><s>[INST]Generate a response to this objection.[/INST]Per our conversation, the Company will allow the insured to change options at any time. We have updated our amendatory endorsement accordingly.</s><s>[INST]Generate another objection to this filing.[/INST]As previously stated, We note additional companies are referenced within the filing. Pursuant to K.A.R. 40-1-15 please clarify the additional companies referenced, as they are not listed within this filing, and please amend the filing accordingly. It is noted you have have advised the forms will only be used for Cimarron Insurance Company, Inc. as such we ask you remove all other companies from the forms to comply with our statutes.</s><s>[INST]Generate a response to this objection.[/INST]Per our conversation, Kanguro is a duly licensed producer in your state and will be the producer of record for this program. Cimarron Insurance Company, Inc. will be the carrier for this program. As both entities are duly licensed in your state, we respectfully request that the state reconsider its position. We believe that it is common for the producer's logo to appear on insurance forms.</s><s>[INST]Generate another objection to this filing.[/INST]Please remove the "john doe" version of the form from the forms tab to the supporting documents tab and submit a clean print ready version of the form under the forms tab for review and approval.</s><s>[INST]Generate a response to this objection.[/INST]Please refer to the attached clean dec page.</s><s>[INST]Generate another objection to this filing.[/INST]In reviewing the captioned forms, we find multiple brackets to signify variable language. Please provide this department with an exhibit of all possible variables used in the brackets. This appears necessary to avoid a potential violation of K.S.A. 40-216.</s><s>[INST]Generate a response to this objection.[/INST]Please refer to the attached "statement of variability" versions of the Declarations Page and Preventive Care endorsement.</s><s>[INST]Generate another objection to this filing.[/INST]Pursuant to K.S.A. 40-216, insurance companies must file all forms utilized in the transaction of business in Kansas. K.A.R. 40-3-5 further requires that, regardless of bureau affiliation, all basic policy forms and jackets must be filed. Please submit the following additional forms: policy jackets application (if attached to the policy or if it will bind coverage), notice of cancellation and nonrenewal for Kansas or equivalent, certificate of insurance (K.S.A. 40-955), insurance identification card (K.S.A. 40-3104)</s><s>[INST]Generate a response to this objection.[/INST]a.Our application for insurance is done online via Get a Quote on our website www.kanguroinsurance.com b.Once the customer purchases the policy they get a welcome email with all the policy jacket (dec page, policy doc, state forms, preventive endorsement) as well as credentials to log into the APP which is in any app store (IOS or Android) c.The customers get can see their policy (equivalent of insurance ID cards). See attached for example screen shotes. Where they track coverage/usage and anything else related to the policy d.Customers submit claims on the app or email but attached are our claim forms</s><s>[INST]Generate another objection to this filing.[/INST]Pursuant to K.S.A. 40-955(i) and K.S.A. 40-216 personal lines filings must be on file for 30 days before becoming effective. Please select a new Effective Date via post submission update.</s><s>[INST]Generate a response to this objection.[/INST]My apologies - I have updated the effective date via PSU.</s><s>[INST]Generate another objection to this filing.[/INST]Kansas does not review or regulate the rates for pet insurance, pursuant to KAR 40-3-24, please withdraw the rates from this filing.</s><s>[INST]Generate a response to this objection.[/INST]We have withdrawn the rates accordingly.</s><s>[INST]Generate another objection to this filing.[/INST]In reviewing the captioned form, we find multiple brackets to signify variable language. Please provide this department with an exhibit of all possible variables used in the brackets. This appears necessary to avoid a potential violation of K.S.A. 40-216.</s><s>[INST]Generate a response to this objection.[/INST]The only variable information that gets filled in are the annual limits ($5,000, $10,000, $15,000. $20,000, $30,000), reimbursement rates (70%,80%,90%), and deductible ($200, $500. $700, $1,000)</s><s>[INST]Generate another objection to this filing.[/INST]K.S.A. 16-1605(b), K.S.A. 40-5802, K.S.A. 40-5804(c)(1) and K.S.A. 40-5804(c)(2)(B) establishes the Electronic Notice and Document Act which allows the use of electronic means for sending insurance notices and documents. In order to send electronic notices and documents to another party, the insurer must obtain the consent of the insured. Additionally, an insured who has opted in should have a mechanism to opt out if so desired. Please amend the filing to comply with these statutes. Please amend to advise how the insured would change a selection once the policy is in place. SERFF Tracking #: WESA-133479632 State Tracking #: WESA-133479632 Company Tracking #: PIP-22-001 (KS) State: Kansas Filing Company: Cimarron Insurance Company, Inc. TOI/Sub-TOI: 09.0 Inland Marine/09.0004 Pet Insurance Plans Product Name: Pet Insurance Program Project Name/Number: Pet Insurance Program /PIP-22-001 PDF Pipeline for SERFF Tracking Number WESA-133479632 Generated 01/05/2023 12:39 AM</s><s>[INST]Generate a response to this objection.[/INST]The Company will reply on the attached ACORD form.</s><s>[INST]Generate another objection to this filing.[/INST]We note additional companies are referenced within the filing. Pursuant to K.A.R. 40-1-15 please clarify the additional companies referenced, as they are not listed within this filing, and please amend the filing accordingly.</s><s>[INST]Generate a response to this objection.[/INST]This filing and its forms will only be used by Cimarron Insurance Company.</s>
<s>[INST]<<SYS>>Review this pet insurance filing. Company: CUMIS Insurance Society, Inc. Product: BIVVY State: Kansas Date: 02/27/2023 Description: Filing Description: SERFF Tracking #: CUNA-133576815 State Tracking #: CUNA-133576815 Company Tracking #: 2023 BIVVY NON-RENEWAL State: Kansas Filing Company: CUMIS Insurance Society, Inc. TOI/Sub-TOI: 09.0 Inland Marine/09.0004 Pet Insurance Plans Product Name: BIVVY Project Name/Number: 2023 BIVVY NON-RENEWAL/ PDF Pipeline for SERFF Tracking Number CUNA-133576815 Generated 03/16/2023 02:51 A <</SYS>> Generate an objection to this filing.[/INST] Please revise the seventh paragraph in the Filing Description to state the revised date of the last renewal letter. Once this is complete the file will be ready for final review and approval.</s><s>[INST]Generate a response to this objection.[/INST]The seventh paragraph in the Filing Description has been revised with a post submission update.</s><s>[INST]Generate another objection to this filing.[/INST]Please clarify when the last non-renewal will take place. If the insured is given proper notice, and the notices will not be sent until 05/02/2023; please explain how the last non-renewal would be 1/31/2024 when insureds may have renewed from 02/01/2023 - 04/30/2023 would also need to receive proper notice.</s><s>[INST]Generate a response to this objection.[/INST]You are correct. Policies may have renewed and would get a full year of coverage if they choose to keep the policy active. If the first notice of non-renewal is sent on 5/2/2023 then the latest possible date for a non-renewal could potentially be as late as 7/7/2024. Allowing for 65 days of notice to ensure we are always giving customers at least 60-day notice before their actual non- renewal.</s><s>[INST]Generate another objection to this filing.[/INST]Pursuant to K.S.A.40-2,123 please select an effective date 60 days after the date this filing was made as this filing is to notify the DOI of the withdrawal.</s><s>[INST]Generate a response to this objection.[/INST]The filing was submitted on 2/27/2023, the first opportunity for us to begin initial non-renewal notices meeting the 60 day requirement would be 5/2/2023.</s><s>[INST]Generate another objection to this filing.[/INST]It is noted that two letters provided note previous communication via e-mail. Please advise if any customers with the BIVVY product have elected to not conduct business electronically. If any insured have elected to not conduct business electronically, please provide a copy of the second letter those insured would receive.</s><s>[INST]Generate a response to this objection.[/INST]We have attached hard copy versions of the letters which would be mailed to any customers who elected to not conduct business electronically.</s><s>[INST]Generate another objection to this filing.[/INST]Please attach a copy of the letter that was sent to the DOI advising of the withdrawal of this program.</s><s>[INST]Generate a response to this objection.[/INST]We have attached this letter to the supporting documentation tab.</s><s>[INST]Generate another objection to this filing.[/INST]Please advise when the company will begin sending the provided letters out to the insured as this has not been noted previously.</s><s>[INST]Generate a response to this objection.[/INST]If properly approved, we will begin initial notifications of non-renewal on 5/2/2023.</s><s>[INST]Generate another objection to this filing.[/INST]Please provide an informational copy of the letter that was sent to the DOI advising of the withdrawal of the program.</s><s>[INST]Generate a response to this objection.[/INST]This letter has been attached to the supporting documents tab.</s><s>[INST]Generate another objection to this filing.[/INST]Please also supply a copy of the non-renewal letter that will be sebt to the insured.</s><s>[INST]Generate a response to this objection.[/INST]There are 4 communications that will be used. Two initial notice emails and two final notice emails. For policyowners who have dogs and cats, an offer of Spot Pet Insurance is included in the notices. For policyowners with other family pets, the initial notice and final notice do not include an offer of Spot Pet Insurance. Pets other than Dogs and Cats are not eligible to purchase Spot Pet insurance. The four files have been attached to the supporting documents tab. </s>

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