The Financial Services Commission of Ontario (FSCO) is releasing updated filing guidelines for submitting changes to automobile insurance rates and risk classification systems. These filing guidelines are effective immediately. Insurers may continue to submit rate filings to FSCO using the rate filing guidelines issued in November 1996 until March 31, 2001. As of April 1, 2001, all filings must follow the new filing guidelines format. Also, FSCO is releasing updated Technical Notes to assist insurers in preparing rate filings.
FSCO engaged a consulting firm to review the rate filing process in Ontario. These filing guidelines have been developed based on the recommendations of the consulting firm, and an industry working group’s review of the recommendations. We appreciate the assistance provided by the working group members in the development of these guidelines.
Changes to the Rate Filing System
Insurers will see a number of improvements to the filing process which include the following:
- a new filing process for changes to private passenger automobile insurance rates has been introduced. Insurers that meet the criteria set out in the Technical Notes, can file for changes to base rates, all existing differentials, discounts/surcharges, rating rules and definitions through the Respond to Market (R2M) process. Insurers can introduce rating variables, discounts or surcharges if they can demonstrate that they are used by another automobile insurer in Ontario. This new process will enable insurers to more rapidly respond to market conditions as less detailed filing information is required and FSCO’s review process will be quicker;
- the criteria for the R2M process have been established by the Superintendent and are to be updated annually, effective January 1 of each year, based on the effective renewal date of the proposed changes;
- the standard information required within Appendix A for all rate filings has been streamlined;
- a simplified filing guideline package (Section 413 Filing Guidelines - Minor) has been developed for filing changes for categories of automobile insurance other than private passenger automobile. However, a company may be requested by FSCO to file rate indications with actuarial support using Section 413 Filing Guidelines - Major, where for example, the company is requesting a large rate change or is a large writer in the category of insurance;
- while manual pages that describe the current and proposed changes to rules or definitions must be provided within a filing, the manual pages setting out rates by territory, driving record, etc. only need to be submitted after the filing has been approved; and
- rates for categories of automobile insurance that are dependent on one another (e.g. motorhome rates that are dependent on private passenger automobile insurance rates) must now be submitted within a single filing.
There are now five different filing guidelines, depending upon the types of changes proposed:
- Section 410 Filing Guidelines - Expedited
- Section 410 Filing Guidelines - Respond to Market (R2M)
- Section 410 Filing Guidelines - Major
- Section 413 Filing Guidelines - Minor
- Section 413 Filing Guidelines - Major
FSCO has also updated the Technical Notes that were originally issued in 1996. These Technical Notes are provided to assist insurers in preparing filings by identifying common issues that arise through the filing process and are considered to be part of the application (filing) for approval or authorization of rates and risk classification systems under sections 410(3) and 413(2) of the Insurance Act. The Technical Notes also provide an example of a filing that qualifies for the R2M process. Also included within the Technical Notes are benchmark assumptions FSCO uses in reviewing rate filings. Both the R2M criteria and benchmark assumptions will be reviewed and updated annually.
FSCO is currently developing a web-based electronic filing system for automobile insurance filings based on these revised filing guidelines. This will enable insurance companies to complete standard appendices electronically, and attach non-standard exhibits for submission to FSCO.
Should you have any inquiries regarding this bulletin, please contact your rate analyst in the Automobile Insurance Analysis Division at FSCO. Please note that this bulletin, the filing guidelines and the Technical Notes are posted on FSCO's website at: www.fsco.gov.on.ca under Insurance - Auto Insurance - Filing Guidelines for Insurance Companies.
Chief Executive Officer and
Superintendent of Financial Services
February 5, 2001