Compared to personal lines, commercial lines risks have larger policy premiums, more complicated coverage, and higher limits. Commercial lines risks are also less homogeneous than personal lines risks. Consequently, individual underwriting is often used and there is a greater need for flexibility in pricing these risks.
That said, with some exceptions, commercial lines rates are subject to filing and Department of Insurance (“DOI”) acknowledgment or approval. For this reason, it is advantageous for the commercial lines insurer to incorporate rating flexibility in their commercial lines rate manuals.
Here we will examine the top four considerations for building a flexible and robust commercial lines rating plan.
Schedule Rating/Individual Risk Premium Modification (“IRPM”)
Schedule Rating/IRPM Plans are one of the most common means of achieving greater flexibility in commercial lines filings. Further, they are allowed in almost all states. The range of flexibility that can be achieved through schedule rating varies by jurisdiction. While many states allow overall schedule rating debits and credits of +/-25%, many other states allow a larger overall debit and/or credit. That said, some states impose different levels of flexibility for each individual characteristic while some states have other requirements (for example, eligibility criteria). A review of your Schedule Rating/IRPM Plan can help ensure that you are achieving maximum rating flexibility via this highly accepted rating tool.
Another way to achieve flexibility in a commercial filing is to include tiering. Tiering refers to rating manuals that contain more than one set of rates to address different pricing levels associated with different levels or tiers of risk. Tiering is more common with Standard commercial lines (e.g. Commercial Auto, Commercial Property, General Liability, etc.) than with Specialty lines (e.g. D&O and Excess Liability). There are two types of tiering:
Intra-company tiering –A single company includes multiple tiers within a single program (e.g. Preferred, Standard, Non-Standard, etc.). Depending on various criteria, a risk might be assigned to a tier with a lower or higher rate.
Inter-company tiering –An insurer group uses different affiliated underwriting companies to accommodate the above-referenced tier structure.
Tiering is allowed in all states for most Standard commercial lines with some exceptions. While generally accepted for most Standard commercial lines, states differ regarding the filing of applicable underwriting criteria and some even limit the characteristics that can be considered.
Ranges of rates or rating factors
While tiering is more commonly applied to Standard commercial lines, ranges (sometimes referred to as guide (a) rating) are more common with Specialty commercial lines. With ranges of rates or ratings factors, an underwriter chooses a rate or rating factor from the filed range. While many states allow ranges, some states strictly prohibit ranges and others allow with certain limitations or additional requirements.
Individual Risk Rating
Individual Risk Rating, also known as (a) rating and/or Refer to Company rating, refers to those instances where manual rates are not used to determine a risk’s premium. Instead, underwriting judgment is used to evaluate the unique characteristics of the risk and to determine the final premium. This may also include a review of a risk’s historical experience.
Individual Risk Rating is used in both Standard and Specialty commercial lines. For Standard commercial lines, Individual Risk Rating may only apply to a particular segment of the business whereas it may be used more extensively for Specialty commercial lines. The acceptability of Individual Risk Rating varies by state with some states prohibiting the practice, and others allowing it. However, even for those that allow it, there are additional requirements that may apply by state such as individual risk submission filings, reporting requirements, disclosure requirements, etc.
While there are many tools available that allow for a flexible and robust rating plan, a thorough and thoughtful review of your new or existing rating plan can ensure that you achieve the greatest flexibility while minimizing compliance issues and DOI objections that may result in delays, reduced flexibility, and/or inconsistencies in your plan across various jurisdictions.
Partnering with an actuarial services firm that is familiar with DOI regulations and positions on the above-referenced rating tools can help you optimize the flexibility of your commercial lines rating plan. This flexibility will allow you to more accurately price your product and will allow you to maximize competitiveness while being mindful of the various requirements associated with each pricing tool.