Articles of Interest
California adopts revised statistical plan regulations
August 27, 2009
The California Department of Insurance has filed revised statistical plan regulations with the California secretary of state. Read on to find out what data will be collected and how soon title insurers will have to submit the revised forms.
The California Department of Insurance has filed revised statistical plan regulations with the California secretary of state. The new regulations will be effective Sept. 3.
The initial submission of the new Statistical Plan and Income Statement will cover experience from Jan. 1, 2011, through Dec. 31, 2011. For subsequent years, all submissions will include data from the current year and the previous year. Insurers will be required to file initial submissions to the Department of Insurance no later than May 31, 2012. Each following submission will be due no later than May 31 of each successive year.
The text of the final regulations states that each submission must be completed using the spreadsheet templates provided by the commissioner of insurance at the “statistical plans” link found on the California Department of Insurance Web site.
Each submission must include the following:
- Company Information (Signature Page/Certification) form
- General Interrogatories Page
- CATI-R1: Income Statement
- CATI-R2: Summary of Transaction Activities
- CATI-R3 [Parts 1 to 6]: Summary of Rate Distribution by Type of Policy
- CATI-R3 Total [of Parts 1 to 6]: Summary of Rate Distribution by Type of Policy
- CATI-R4.1: Escrow Fee Distribution by Amount of Transaction (by County)
- CATI-R4.2: Summary of Escrow Fees by County
According to the California Land Title Association (CLTA), the final regulations clarify that only title insurers must file these data reports. However, the departments require them to report both title and escrow loss and loss adjustment expenses.
The CLTA also noted that the reporting of unusual risk premium charged pursuant to Insurance Code Section 12401.8 will still be included in these reports. Insurers must provide the unusual risk premiums of direct operations, non-affiliated agency and affiliated agency operations. Insurers will also still be required to report total escrow fees from direct operations for unusual services charged pursuant to Insurance Code Section 12401.8 for California amounts.
The text was revised on June 22 after submitting original text for comment on May 7. In a final statement of reasons released June 22, the commissioner noted, among other things, that after the comment period the department added two questions to the interrogatory page. The answered questions will provide the department with information regarding the reporting companies’ methods in completing the Escrow Fee Distribution report.
The department also amended many specific line items of the income statement instructions in response to comments it received from trade groups and individual members of the title insurance industry.
“Generally, the descriptions of the income statement line items were amended to conform to the NAIC Annual Statement reporting,” the Final Statement of Reasons stated. “Some line items were deleted as unnecessary. All the changes — amendments and deletions —were reasonably necessary to improve the quality of data the department receives by either providing clarity or to striking a proper balance between sufficient information and undue burden.”
