Q2 2025 State Filings Pulse: New York Top Five Objections, California Filing Rejection Rate Skyrockets, Approval Times by State and More
- Written By Brett Horoff
Perr&Knight has published the Q2 2025 edition of State Filings Pulse, providing the latest insights into state specific filing news, approval times by state and other filing statistics.
To receive a free copy of State Filings Pulse each quarter, click here to register: https://www.perrknight.com/insights/guides-white-papers/state-filings-pulse/
Key Highlights from the Q2 2025 Edition
New York Top Five Objections
During the last 12 months, New York has disapproved 12% of all filings with a disposition. This has been a fairly consistent ratio from 2023 to 2025. The time to approval has been increasing in the state for rate filings as follows:
- All Lines: 58 days in 2023 to 120 days for 12-months ending 06/30/2025
- Homeowners: 62 days in 2023 to 233 days for 12-months ending 06/30/2025
- Personal Auto: 90 days in 2023 to 157 days for 12-months ending 06/30/2025
- Commercial & All Other Personal: 38 days in 2023 to 88 days for 12-months ending 06/30/2025
Below are the top five objections, which were gathered by our consulting actuary experts and product design consultants reviewing publicly available filings over the last 12 months.
- Issues with Rate Filing Sequence Checklist Items:
- Exhibit RT-2 (Policyholder Rate Level Changes): Missing histogram including a step-by-step derivation of the RT-2 histogram data.
- Exhibit RT-1 (Side-by-Side Comparison): Missing side-by-side comparison. Red-lined manual pages do not satisfy this requirement.
- Exhibit JDG-1 (Explanation of Key Areas of Judgment): Insufficient or no support for judgment.
- Clarification on whether a form is mandatory or optional, and objecting that optional forms with coverage effects must have an associated rate reduction to avoid unfair discrimination.
- Side-by-side comparison for new forms based on or similar to a form that was previously approved by this Department.
- Failure to outline all the proposed changes in the explanatory memo.
- Not including State Tracking Numbers for referenced competitors, Rating Service Organization Adoptions or prior filings, when applicable.
According to our consulting actuary experts, it is fairly common for filings to not be fully compliant with the New York Rate Filing Sequence Checklist instructions. They recommend reviewing this before each filing and establishing templates with all the required information to ensure compliance.
California Filing Rejection Rate Skyrockets
As mentioned with the release of Q1 2025 edition of State Filings Pulse, the rejection rate for rate filings in California has jumped since the implementation of the Complete Rate Application (CRA) regulation in October 2024 (CCR §2648.4). Below is the latest update.
- 2024: 3%
- Q1 2025: 14%
- Q2 2025: 30%
One of the main reasons filings are rejected is due to data reconciliation issues. Insurers should be performing all the data checks in California’s Prior Approval Rate Application – Data Quality and Reconciliation Checklist. If the Company has reasons for any data reconciliation differences, these should be explained in the filing. To help insurers comply, the Department has developed a Prior Approval Rate Application (PARA) Portal and Data Reconciliation Tool. The beta version is currently being tested by participating insurers.
If you are one of the insurers having issues with filings being rejected in California, Perr&Knight’s actuarial experts can review filings prepared by insurers and recommend changes needed to comply with the state’s requirements. This includes running the data through Perr&Knight’s proprietary data reconciliation tool.
Time to Approval/Disposition by State
The table below provides a detailed breakdown, by state, of the median time to approval or disposition, based on data from State Filings Pulse, for the 12-month period ending June 30, 2025.
Excluding Rate Filings1,2
| Approval Time Range (Days) | Homeowners | Personal Auto | Commercial & Other Personal |
| 0–303 | AL, AR, AZ, ID, IL, IN, KS, KY, LA, MI, MN, MT, NC, NE, NM, OK, OR, SD, UT, WI, WV, WY | AL, AR, AZ, ID, IL, IN, KS, KY, LA, MN, MS, MT, NC, NE, NM, OK, OR, SD, TN, UT, WI, WV, WY | AR, AZ, CT, FL, GA, ID, IN, KS, KY, LA, MA, MI, MN, MS, MT, NC, NE, NH, NM, OK, OR, PA, SD, TN, UT, VT, WI, WV, WY |
| 31–59 | AK, CO, GA, MO, MS, ND, NH, OH, PA, TN, VA | AK, CT, GA, MA, MI, MO, ND, NH, NV, OH, VA | AK, AL, DC, DE, IA, IL, ME, MO, ND, NV, OH, RI, SC, VA |
| 60–89 | CT, DE, IA, ME, NJ, VT | DE, IA, ME, NJ, PA, RI, SC, TX, VT | HI, NJ, NY, TX |
| 90–119 | DC, MA, NV, SC, WA | FL | WA |
| 120–149 | HI, RI, TX | CO, DC, WA | MD |
| 150–179 | FL | NY | CO |
| 180–269 | MD, NY | CA, HI, MD | None |
| 270–359 | CA | None | CA |
| 360+ | None | None | None |
Excluding Rate Filings1,2
| Approval Time Range (Days) | Homeowners | Personal Auto | Commercial & Other Personal |
| 0–303 | AK, AL, AR, AZ, CT, DE, FL, GA, IA, ID, IL, IN, KS, KY, LA, ME, MI, MN, MO, MS, NC, ND, NE, NM, NV, OH, OK, OR, PA, RI, SC, SD, TN, UT, VA, VT, WA, WI, WV, WY | AK, AL, AR, AZ, CT, DE, FL, GA, IA, ID, IL, IN, KS, KY, LA, MD, ME, MI, MN, MS, NC, ND, NE, NM, NV, OH, OK, OR, PA, RI, SC, SD, TN, UT, VA, VT, WA, WI, WV, WY | AK, AL, AR, AZ, CT, DE, FL, GA, HI, IA, ID, IL, IN, KS, KY, LA, MA, MD, ME, MI, MN, MO, MS, NC, ND, NE, NH, NM, NV, NY, OH, OK, OR, PA, RI, SC, SD, TN, UT, VT, WA, WI, WV, WY |
| 31–59 | CO, DC, HI, MA, MD, MT, NH | CO, HI, MA, MO, MT, NH, TX | MT, NJ, TX, VA |
| 60–89 | NJ, NY | CA, DC, NY | CO, DC |
| 90–119 | CA | NJ | CA |
| 120–149 | None | None | None |
| 150–179 | None | None | None |
| 180–269 | TX | None | None |
| 270–359 | None | None | None |
| 360+ | None | None | None |
- For states where the filing law is “file and use” or “use and file”, insurers may use the filing prior to the state issuing an approval/disposition.
- Includes filings with approval/disposition dates during the period 07/01/2024 to 06/30/2025.
- Includes states exempt from filing.
The Q2 2025 edition includes data spanning from January 2020 through June 2025, providing long-term trends and comparisons across states.
Download the June 2025 Edition of State Filings Pulse
The full report includes additional state filing statistics.
👉 Download your free copy of State Filings Pulse here: https://www.perrknight.com/insights/guides-white-papers/state-filings-pulse/, and contact Perr&Knight for further information or consultation.
