California Requires PPA Filings by July 1, 2023 Due to Minimum Financial Responsibility Limits Change

On January 30, 2023, the California Department of Insurance (“CDI”) issued BULLETIN 2023-1 to remind all private passenger automobile liability insurers of their current obligation to file Prior Approval Rate Applications (“Rate Application”) with the CDI’s Rate Regulation Branch by July 1, 2023 to account for the updates to the financial responsibility laws going into effect on or after January 1, 2025 pursuant to Senate Bill 1107 (Dodd, Chapter 717, Statutes of 2022).

Below we have summarized the key information.

REQUIRED CHANGES

• Increase minimum coverage liability limits to $30,000 for bodily injury to or death of one person in any one accident.
• Increase minimum coverage liability limits to $60,000 for bodily injury to or death of two or more persons in any one accident.
• Increase minimum coverage liability limits to $15,000 for property damage caused by any one accident.

DETAILS FOR RATE APPLICATION FILINGS

• This Rate Application shall be filed with the sole purpose of introducing the new limit options (“FR limits”) for Bodily Injury, Property Damage, and Uninsured Motorist/Underinsured Motorist to comply with the foregoing changes to the financial responsibility laws.
• Submit the Rate Application as filing type “Rule filing without rate impact,” and program name “FR Limits 2023.”  There shall be no changes to rating relativities to existing limit options or any other rating elements in the insurer’s rating plan in this rule filing.
• Provide support for the rating relativities for the newly introduced FR limits in Rate Application Exhibit 19-A, Supplemental Information.
• For insurers that currently offer the new FR limits, submit the Rule filing without rate impact as delineated above, excluding support for relativities. The insurer must attest to the existence of these limit offerings in the Filing Memorandum and identify where those limits can be found in the insurer’s rate and rule manual included in the filing.

NEED HELP WITH YOUR CALIFORNIA FILINGS

Perr&Knight is a leading provider of actuarial and state filing services to insurers in California. Our actuarial consulting team actively follows the California market and is very familiar with all the filing requirements in the state. We prepare and submit more California filings than any other company.

Please contact us for any insurance filings support that is needed with your California insurance products.