As the insurance industry struggles toward economic recovery along with everyone else, webinars have proven to be a cost-efficient way for interested parties to meet and share complex information. With the goals of taking in better filings and providing faster turnaround, the New York State Insurance Department recently gave property and casualty insurers the opportunity to attend a webinar clarifying “me too” filings. So, I poured a fresh cup of coffee, joined the meeting and prepared to be informed by P&C Deputy Chief Examiner Moe Morgenstern, ably assisted by veteran regulator Gerry Scattaglia. To oversimplify the matter, the “me too” filing has always seemed like such a convenient way to file: simply refer to Alpha company’s prior approved filing and indicate that Beta company would like to implement the exact same program without the need for all those detailed forms and supporting exhibits . . . not so fast. As the regulators immediately clarified, in New York, a “me too” filing cannot be made by referencing another insurer’s approved rate, forms/endorsements filing; it is by definition a filing that references a rate service organization (RSO) prior approved form or rate filing only. A “me too” filing cannot modify the loss costs/rates of an RSO.
The NYSID website can be daunting to navigate and in order to submit a complete filing, it is critical to start at the main filing instruction page – always review the page for updated information and review standards checklists, whether you are submitting the filing via SERFF or in paper format. From this screen, the filer can access detailed “how to” information on completing required forms and exhibits for all filings, including those of the “me too” variety.
When making any filing in New York, the filer must decide whether to utilize the expedited “speed to market” or “regular” filing process, and Mr. Morgenstern provided a few useful tips on when the “speed to market” process is advantageous. A “speed to market” filing is best suited for policy form filings that reflect minor revisions, broadened coverages with no added restrictions, or for filing a new policy that is identical to a policy previously approved for another insurer. “Speed to market” filing can also be used for rate filings that do not reflect large increases or catastrophe reinsurance. Alas, the “speed to market” process is not available for personal or public auto, medical malpractice or worker’s compensation filings.
The Department has made the “me too” presentation available for access anytime on the website . Since expense-paid trips to exotic conference locales are usually out of the question, here’s hoping for more webinars!
