Q1 2025 State Filings Pulse: Maryland Delays, California Bulletin 2024-7 & CRA Update, and Approval Times by State
- Written By Brett Horoff
Perr&Knight has published the Q1 2025 edition of State Filings Pulse, providing the latest insights into U.S. insurance regulatory activity. This edition highlights approval time trends, state-specific filing updates, and notable regulatory developments.
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 Q1 2025 Edition
Maryland Sees Significant Delays in Rate Filing Approvals
Maryland is currently experiencing a staffing shortage, leading to a backlog in rate filing approvals. While form and rule filings typically continue to be approved within 20 days, the median approval time for rate filings has drastically increased:
- 2023: 25 days
- 2024: 99 days
- Q1 2025: 185 days
Insurers with business in Maryland should adjust filing schedules accordingly to accommodate extended processing times.
California Bulletin 2024-7 Update: Implementation Delayed
In an effort to reduce rate filing delays, California Insurance Commissioner Ricardo Lara issued Bulletin 2024-7 on August 9, 2024, introducing a new filing review framework:
- 30 days: Public notice period
- 60 days: Initial review window
- +30 days: Two possible extensions
- 10 days: Insurer decision window
If an insurer accepts the rate calculated by the Department, the process could be completed in as little as 160 days. However, implementation is pending the deployment of a required data reconciliation tool.
As of March 2025, the Department has not issued a Request for Proposal (RFP) for this tool, pushing estimated implementation to late 2025 at the earliest.
Despite delays, California’s median rate filing approval times have improved:
- 2022: 398 days
- Q1 2025: 272 days
California CRA Regulation Drives Increase in Filing Rejections
Since the introduction of the Complete Rate Application (CRA) regulation in October 2024 (CCR §2648.4), the rejection rate for rate filings in California has jumped:
- 2024: 3%
- Q1 2025: 14%
The CRA requires completeness and consistency across all supporting documentation—including the Rate Application, Rate Template, Standard Exhibit, and Supporting Exhibits. Filings with significant deficiencies are rejected outright. For minor issues, objections may be raised if the Department has sufficient time within the 30-day CRA review window.
Insurers are encouraged to thoroughly review all documentation for completeness and accuracy to reduce the risk of rejection under CRA regulations. To support this effort, Perr&Knight’s actuarial experts have developed a robust data reconciliation tool that enhances the accuracy of rate filings prepared and submitted by our state filings team.
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 March 31, 2025.
Rate Filings
| Approval Time Range (Days) | Homeowners | Personal Auto | Commercial & Other Personal |
| 0–30 | AL, AR, AZ, ID, IL, IN, KS, KY, LA, MI, MT, NC, NE, NM, OK, OR, SD, UT, WI, WV, WY | AL, AR, AZ, ID, IL, IN, KY, LA, MN, MS, MT, NC, NE, NM, OK, OR, SD, UT, WI, WV, WY | AR, AZ, CT, FL, GA, ID, IN, KS, KY, LA, MA, MI, MN, MS, MT, NC, NE, NM, OK, OR, PA, SD, TN, UT, VT, WI, WV, WY |
| 31–59 | AK, GA, MN, MO, MS, ND, NH, OH, PA, TN, VA, VT | AK, GA, IA, KS, MA, MI, MO, ND, NH, OH, TN, VA, VT | AK, AL, DC, DE, HI, IA, IL, ME, MO, ND, NH, NV, OH, RI, SC, VA |
| 60–89 | CO, CT, DE, IA, MA, ME | CT, ME, NV, PA, SC, TX | MD, NJ, NY, TX |
| 90–119 | DC, NJ, NV, SC, TX, WA | DE, FL, NJ, RI, WA | WA |
| 120–149 | HI, RI | CO, DC | None |
| 150–179 | None | NY | CO |
| 180–269 | FL, MD, NY | CA, HI, MD | None |
| 270–359 | CA | None | CA |
| 360+ | None | None | None |
Excluding Rate Filings
| Approval Time Range (Days) | Homeowners | Personal Auto | Commercial & Other Personal |
| 0–30 | AK, AL, AR, AZ, CT, DE, FL, GA, IA, ID, IL, IN, KS, KY, LA, ME, MI, MN, MO, MS, NC, ND, NE, NH, 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, 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, HI, IA, ID, IL, IN, KS, KY, LA, MA, MD, ME, MI, MN, MO, MS, MT, NC, ND, NE, NH, NJ, NM, NV, NY, OH, OK, OR, PA, RI, SC, SD, TN, UT, VT, WA, WI, WV, WY |
| 31–59 | CO, HI, MA, MD, MT | CO, MD, MT, NH, TX | TX, VA |
| 60–89 | DC, NY | DC, NJ | CO, DC |
| 90–119 | NJ | CA, NY | CA |
| 120–149 | CA, TX | None | None |
| 150–179 | None | None | None |
| 180–269 | None | None | None |
| 270–359 | None | None | None |
| 360+ | None | None | None |
The Q1 2025 edition includes data spanning from January 2020 through March 2025, providing long-term trends and comparisons across states.
Download the March 2025 Edition of State Filings Pulse
This summary includes just a few of the insights available in the full report. The March 2025 edition also features:
- Filing volume trends
- State-specific approval performance
- Longitudinal statistics for strategic planning
👉 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.
