How to Get a Commercial Lines Filing Approved in the State of Washington

The State of Washington has some of the most thorough actuarial / competitive analysis support requirements for rate filings out of all 51 U.S. jurisdictions. To obtain approval on a commercial lines new program or a rate filing revision, specific steps must be followed, or your chances of approval quickly diminish. Based on decades of actuarial consulting to insurance companies writing business in Washington, we have seen what helps improve the chances of speedy approval – and what gets in the way. Following the below steps will help ensure a more timely approval in this highly regulated state. 

New Program Filings:

Bureau Based Filings

Filing to adopt the loss costs and rules of the Insurance Services Office (“ISO”), for example, is a type of bureau-based filing. While these are the easiest to obtain state approval – since the bureau loss costs are already approved – you are still required to support the loss cost multiplier (“LCM”) and any state exceptions. The LCM consists of commissions, taxes/licenses/fees, other acquisition expense, general expense, and profit load. These must be supported based on your historical expenses (or industry expenses if historical data is not available) and should not deviate from the historical averages without support. For long tailed lines, like commercial auto liability and commercial general liability, you must also include an increased limit factor (“ILF”) risk load offset in the LCM (which tends to lower the overall LCM from the indicated). In addition, deviating from the LCM, which is usually done by incorporating a loss cost modification factor (“LCMF”), requires full support either from competitors approved in the state or historical data. 

Independent Rating Plans

If your rating manual is not based on a rating bureau, you will need full support for the base rates and any rating factors in the proposed rating plan. If your rating plan is not an exact copy of an approved Washington competitor’s rating plan, any deviations will need to be supported with a competitive analysis. A comparison of base rates and all rating variables will be required to ensure they are not inadequate, excessive, or unfairly discriminatory. In addition, expense offsets are required as discussed in more detail below.

Filings Based on Competitors

Our lengthy actuarial consulting experience in Washington has shown us that one of the best ways to get an independent rating plan approved is to base your filing on another approved Washington competitor manual. You must supply the Department with the SERFF# as well as the Washington Department approval # on any competitor analysis. Note that any deviation from that competitor plan must be fully supported using other approved competitors or with applicable historical premium/loss data. 

While Washington technically does not permit filings based on other competitors, they are permissible if you derive the loss costs of your competitors and load in your own underwriting expenses and profit load. A filing will not be approved without using this method to derive the base rates, so it is likely that your Washington rating manual will deviate from the manual you are using in other states. It is also very possible that the competitor manual upon which you want to base your rates is not approved in Washington, meaning you may need to select a different, Washington-approved competitor.

Return on Equity Exhibits

These are required in your filing submission to support the underwriting expenses and profit load, but unlike most other states, Washington is only interested in your return on insurance operations, not your total return on equity. The return on insurance operations, in general, cannot be above 5.0%. Many times, profit load, or other figures in the exhibits, require adjustments to pass this requirement. While there are other alternative methodologies the Department permits, making adjustments to a return on equity model is usually the best way to meet this requirement. For Bureau based filings, it is also likely that your LCM will be different in Washington compared to other states.

Filing Memo

Explaining the derivation of your rates in detail is important to obtain approval. You should explain the exact steps taken to develop the rating manual, providing your step-by-step process to derive the rates and rating factors. Further, each insurer must include the name of its statistical agent, per statute requirements. It is possible to not receive any objections from Washington and get a timely approval if all the above guidelines are carefully followed.

Rate Filing Revisions:

Actuarial Support

If you are making a rate revision to a currently approved program, any changes need to be fully supported. If you are taking a base rate increase, in general, an overall rate level indication is required. A rate indication indicates the estimated rate change necessary on an aggregate basis. If you are making any changes to your rating variables, a class plan analysis is required. A class plan analysis will review some or all the rating variables in your rating manual, based on data availability, excluding the base rate. If you are looking to make a rate revision based on competitor rates rather than actuarial data, a detailed competitor analysis is required, showing how the base rate or rating factor deviations are justified. 

Actuarial Memo

While a filing memorandum is necessary for a new program filing, an actuarial memo is required for a rate filing revision when historical data is used to support your filing. Your rate level impact should be in line with the rate level indication (i.e. an increase / decrease should not be above / below the indication). If you are making changes to rating variables, it is important that your class plan analysis supports each change accordingly. Always give as much detail as possible supporting why you selected a particular change to a rate or rating factor to prevent unnecessary questions.

Do you need guidance on how to get your Washington new program or filing revision approved to improve speed to market? Contact the actuarial consulting experts at Perr&Knight today. 

Tips for Adding Flexibility to Your Commercial Lines Rating Plan

Every company writing commercial insurance products needs flexibility in its filed rates in order to charge the appropriate premium. There are many different types of rating flexibilities in the commercial lines insurance marketplace for admitted state filings, but the terminology is somewhat confusing and is often misunderstood. In this summary, we describe each main type of rating flexibility and provide a clearer definition based on our experience with the various Departments of Insurance (“DOI”s) and lines of business.
With some exceptions, commercial lines rates and rules are subject to the DOI’s state filings and approval requirements, similar to personal lines. Commercial lines premiums must also be calculated in compliance with filed rates and rules.
However, commercial lines policy premiums are generally bigger, coverages are more complex, and limits are higher compared to personal lines. As a result, the level of underwriting required for commercial lines is more than personal lines. In addition, risks insured under commercial lines are more heterogeneous, so is difficult for a rating manual to address the rating characteristics of all possible risks. This heterogeneous nature often leads to the need for customized coverage. Also, larger and more sophisticated commercial risks may utilize risk managers to evaluate and mitigate their exposure to loss. To address all of that, commercial lines products require more flexibility in their rating manuals than personal lines.
Incorporating rating flexibilities into a filed commercial lines rate and rule manual can help an insurance company be more competitive, have more accurate premiums and reduce the need for rate filing revisions year over year—saving time and money.
For states that are fully exempt from filing requirements (meaning rates/rules are not required to be filed), companies have more rate flexibility than in states that require filings. Additionally, large risk filing exemptions (which vary by state and are related to number of employees, premium size, etc.) provide companies with greater rate flexibility in determining the appropriate rate for the risk. Below we have addressed the various ways companies add rate flexibility to programs that are filed with the state DOIs.

Schedule Rating Plans

This classic underwriting tool is a table of debits or credits that are applied to the manual rate to reflect the characteristics of an individual insured that are expected to have a material impact on expected loss.
It allows the underwriter to adjust an insured’s premium up or down to recognize that they may be better or worse than the average risk while remaining compliant with the filed rates and rules. Schedule rating is meant to address characteristics of the risk which are generally not otherwise reflected in the rating manual.
Most DOIs allow Schedule Rating plans, but the requirements regarding maximum overall debits and credits, maximums by risk characteristic and minimum premium eligibility vary by state. It is important to be familiar with each state’s requirements to achieve maximum flexibility while remaining compliant.

Ranges of rates

Many states permit ranges of rates within the base rates and rating factors to allow for additional flexibility in a rating plan. Although allowing this flexibility, some states will require underwriting guidance in the rating manual giving some details on how the factors within the range are selected. Note that ranges of rates are allowed in addition to Schedule Rating plans. In combination, they can provide a significant amount of flexibility.

Refer to Company Rating / (a) rates

Refer to company and (a) rating mean the same thing: they tell a DOI in an admitted filing that a particular risk is difficult to price and the premium calculations will be performed internally (generally by an experienced underwriter) and the actual rate will not be filed.
This is also very similar to (and sometimes used interchangeably with) “Individual risk rating”. While most state DOIs allow individual risk rating, the requirements for state filings vary. First, states have different requirements regarding filing the individual risk rating rule—some don’t require a rule be filed at all, others require a simple rule notifying the DOI of an insurer’s intention to individually rate risks, while some require that the manual include specific formulas and/or procedures that will be used to determine the individual risk premium.
States also differ on the documentation or requirements for state filings when an individual risk rating rule is utilized for individual risk. Some require only that the premium calculation be documented in the underwriting file, while others require that the individual premiums be filed with the DOI. There are also some additional reporting requirements in some states. It is important to be familiar with these requirements to ensure your underwriters use this flexible rating tool compliantly.

Guide (a) rates

This term is used less often in the industry and is usually described as a rating plan that has very large ranges of rates and is proposed as a rough “guide” for rating. The final charged rate is not permitted to go outside the bounds of the large ranges included in the rating plan.
Generally, the ranges are so large, it is very similar to (a) rating (described above) but gives a significant amount of additional flexibility when a DOI does not allow a certain section or manual to be completely (a) rated and is looking for some premium boundaries.


Another method for adding rating reflexibility is tiering, which typically includes three to five tiers with factors below and above one. Criteria such as experience, financial stability and loss prevention are typically used for each tier to differentiate risk.
Where permitted, tiering can be introduced within a single company (intra-company tiering) and/or across multiple companies in a group (inter-company tiering). Intra-company tiering guidelines are required to be filed in most states, but are rarely required to be filed for inter-company tiering. The criteria used in tiering should generally not overlap with the criteria used in the Schedule Rating Plans or rating plans with ranges of rates to prevent double counting.

Consent to Rate

Once an insurance carrier has an approved filing, many DOIs allow consent to rate filings. These generally require a short form signed by the insured showing the premium they will be charged, which will be some amount above (or below, in a handful of states) the premium calculated from the filed and approved rate. In some states, support is also required for the deviation. Filing approval is generally very quick, which may make this the optimal way to achieve a more appropriate rate for the risk. 

Do you need guidance on maximizing the rating flexibilities in your commercial lines rating plans? The state filings experts at Perr&Knight are here to help.

Common Mistakes When Pricing Long-Term Contracts

Developing pricing for long term contracts, specifically auto warranty, poses a tricky challenge for insurers. Determining rates for losses that will not occur until three, five, or seven years into the future requires balancing multiple factors to help ensure profitability and appropriate matching of premium earnings and future losses.
Auto warranties, supplemental tire and wheel coverage, guaranteed auto protection (“GAP”), and other long-term contracts require careful actuarial analysis of multiple variables. Mistakes can be costly – and won’t become apparent until well into the future.
Luckily, by avoiding some of these common mistakes, you can develop pricing for long term contracts that protects your customers and keeps you in the black.

Best in class rating manual structure / pricing flexibility

The long-term contract space, specifically for auto warranty, is much more competitive than ever before, as many insurers and InsurTech companies create brand new programs to corner a piece of this market. Therefore, in order to remain competitive and profitable, insurers must achieve as much flexibility on rating plans as possible. Greater flexibility means you have a higher chance of achieving profitability from the get-go without having to continually refile your rating plans to adjust rates.
Working with actuarial experts who apply expertise with long-term contracts across multiple states can dramatically enhance your pricing process. Actuarial consulting experts can develop a factor-based manual that makes it significantly easier to understand the base rates, rating factors and the impact of rate changes on future policyholders. Determining actual relativities for the main rating variables, along with associated base rates, can turn those old school 500-page “rate cards” into concise rating plans, lessening the time drain on your staff for review and understanding of the material as well as reducing the likelihood of erroneous price quotes and premium reversals.

Misjudging your competition

Competitive analysis provides both a starting point and a point of comparison for your rating plans. It’s a valuable component of the big picture. In addition to jurisdictional and coverage plan comparison, there are two lesser-known areas where you may not be obtaining a true sense of how your pricing stacks up against the competition for auto warranty business.
Less experienced folks in this space may compare rates and factors without thoroughly examining the class plan (actual vehicles) to which these factors are assigned. Not everyone assigns auto classes the same way, so it’s crucial to confirm that you’re looking at comparable plans.
Differences in individual components covered in vehicle service contracts can also throw off the accuracy of your competitive analysis. In order to achieve a true apples-to-apples comparison, you must drill down into individual components of each vehicle service contract to make sure that coverages align.

Incorrect profitability analysis

While you may see your market share rise quickly in this space from a balance sheet perspective, in order to understand profitability, you must earn premium appropriately over the life of the long-term contract. Too much upfront premium earnings may lead you to believe that your loss ratio is strong, but when earned premiums start to slow and losses begin to stack up – there is little that can be done to course-correct at that point. It’s imperative to track your earning patterns alongside your loss development to maintain a consistent loss ratio over time.

Rate level indication inaccuracies

Relying solely on an overall rate level indication can paint an incorrect picture. For example, development of losses will vary considerably on whether a vehicle is new versus used. Similarly, with comparing new cars with say 0-10,000 initial miles versus “new” vehicles with 24,000 to 36,000 initial miles. The rate level indications are generally very different for numerous combinations of new/used, term/length of the contract and initial mileage of the vehicle. It’s important to understand how to best break out each one in order to achieve accurate rate level indications as well as balancing homogeneity and credibility in your data.

Not peer-reviewing your work

If you’re not already writing business in this space, much of the above is likely not apparent. As a result, you may inadvertently begin writing a significant amount of “bad” business while other insurers are steering clear. Even if you have been writing certain types of extended service contracts, it’s easy to fall into oversights that could result in leaving money on the table. Experienced actuarial consulting partners can provide an unbiased, fresh perspective on your work, taking into account product expertise, state-by-state knowledge and a deep understanding of rating plans and rate flexibility to ensure that your rates are reasonable for the associated risk.
As competition in this space rises, insurers are rushing headlong into product offerings that might end up costing them dearly down the line. The old saying, “You can’t fix old business” has never been more applicable than to long-term contracts, because the bottom line is: you’re on the hook until the end of the contract. However, by carefully analyzing each element in your rating and working with an experienced actuarial team comprised of subject matter experts, you can sidestep the mistakes outlined above and develop a proven, competitive and profitable product.

Are your extended service contracts priced correctly? If you’re writing new business or want to double-check current offerings, the actuarial experts at Perr&Knight will let you know if you’re on the right track.

Top 4 Considerations for Building a Robust Commercial Lines Rating Plan

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.

Are you achieving maximum flexibility on your current or new commercial lines insurance product? Our expert actuarial consulting and regulatory compliance teams can help.

How to Get Commercial Lines Rates Approved in Highly Regulated States (CA, FL, NY, TX, WA)

For insurance companies with nationwide products, getting your commercial lines rates approved in heavily regulated states can lead to frustration, confusion and wasted resources. There’s a reason certain states have earned their reputation for being difficult: their requirements are complex and thorough.
This article outlines the most important steps you should take when tackling submissions in highly regulated states to obtain speedy approvals–so you can get on with your business.

Know Your Filing Requirements

Each state has specific requirements that must accompany your filing. Understanding what is and is not required for each state and line of business is key to a timely approval. Carefully examine state filing requirements like return on equity exhibits (which support expenses and profit load), actuarial memorandums, making sure any forms with rate impact have corresponding rates in your manual, understanding the allowable rating flexibilities if any, and how they differ by state, etc. For example, in Florida, many commercial lines rate filings are considered “informational” and don’t require support to be filed, just maintained internally.

Actuarial Transmittals

California, Florida, New York, and Texas require specific transmittals. Every state Department of Insurance expects the filer to fully understand all requirements before submission. Some common transmittals for these states are the California Prior Approval Rate Applications, New York’s Rate Filing Sequence Checklist, the Texas Exhibit L and related actuarial transmittals, and the Florida Rate Level Indications Workbook, Actuarial Memorandum and Actuarial Opinion requirements (only for lines of business where Florida filings are not informational).
Filling out these exhibits is generally very difficult for someone without extensive filing experience.  Completing these documents incorrectly can lead to numerous Department questions or disapproval. In worst case scenarios, poor or incomplete submissions can upset Department staff, possibly making it more difficult to receive approval in the future. 

Actuarial Support Required

The actuarial support required for your filing depends on whether your proposed program is new or a revision. If support is not supplied in the way the specific Department requires, your filing will likely be disapproved and have to be resubmitted. This can add to cost, slow down your timeline and make it more difficult to get approval after resubmission.
Detailed actuarial support/data is generally required for filing revisions with rate level impact. For new programs, detailed competitor support using approved filings in the specific state is often required. Using filings from other states as competitive support will usually not be acceptable.

Responding to Department Objections

When it comes to state filings, it’s best to know your state requirements inside and out, since it is likely you will receive multiple filing questions before approval. Each Department asks different types of questions and each Department is looking for specific responses based on the type of submission. Don’t back yourself into a corner by responding incorrectly or supplying too little (or too much) information during the interrogatory process.
Departments of Insurance are savvy. Reviewing state filings is what they do, day in and day out. The challenge you face is that Departments have very specific requirements and it is difficult to determine the specific details necessary to satisfy their unique stipulations. This is where working with professional insurance support service providers can be a huge help.
When managing filings in highly regulated states, insurance industry experience is invaluable. Many of the clients we help involve situations where the company has submitted a filing incorrectly in one of the above states and requires assistance sorting out the resulting obstacles. Usually, the company’s support data was insufficient or their actuarial transmittals were filled out incorrectly. Completing your filing incorrectly without realizing it ultimately complicates things as you may not know which aspect of your filing needs to be adjusted. It then becomes a difficult puzzle to solve which variables require correction. Each of these steps impedes the process, burning through time and resources.
Outsourcing to insurance experts who have deep experience in the most difficult states, as well as relationships with regulators at the Department of Insurance, streamlines the process and saves you from a costly and lengthy correction and resubmission process. Experts make sure you go through the process methodically, checking and double checking the necessary support before you submit. This will save time and money on the back end, helping to achieve speed to market.