How to read a competitor's rate filing in SERFF

Finding public filings

Many states make filings available to the public through SERFF Filing Access, the NAIC's public search portal; some publish through their own department systems or provide filings on request. Which filings are visible, and how soon after disposition, depends on the state and on the filing. Search by state, line of business (type of insurance), filing type and date range, and narrow by company name when you are looking for a specific carrier.

Start with recent filings for the same line and state as your own. A filing from a different state can still be informative, but the review standards and required exhibits will differ.

Where to look in the filing

Filing description

The filing description is the filer's own summary. It usually states the overall change, the effective dates for new and renewal business, and the main components of the change, such as base rate changes, revised relativities or new rules. Read it first to know what the rest of the filing is supposed to support.

Disposition

The disposition shows the outcome and its date: approved, filed, withdrawn, disapproved or another status the state uses. For rate filings, the rate information typically records the overall indicated change, the overall rate impact, the written premium affected and the number of policyholders affected, where the filer completed those fields. Compare the approved figures with what the filing description requested; a difference often points to something negotiated during review.

Rate and rule schedule

The rate and rule schedule holds the pages that change: rate tables, rules and, often, redlined versions against the pages previously on file. This is where you see exactly which base rates, relativities, territories or rules moved, rather than the summary of them.

Supporting documentation

Supporting documentation usually holds the actuarial memorandum and exhibits: the indication, loss development, trend, credibility, expense and profit provisions, and the distribution of policyholder impacts. Much of the useful detail is here. Some of it may be withheld; see the cautions below.

Correspondence

Objection letters and the filer's responses show what the reviewer questioned and what answers closed the question. Read them in order. Note which points needed more than one round, which ones led to an amended filing, and what kind of support the filer added in response. For how the objection process works, see SERFF objections.

What to extract

Build a short, consistent summary for each filing you read, so filings can be compared:

• Overall change and range. The requested and approved overall changes, and the range of changes by coverage, territory or form where shown.
• Rating variable changes. Which variables or relativities changed, which were added or removed, and how the changes were supported.
• Trend and development selections. Selected loss and premium trends, the trend periods, and the loss development factors or methods used, along with the alternatives the filer showed.
• Credibility and complement. The credibility standard and what the filer used as the complement.
• Expense and profit provisions. The provisions used and how they were sourced.
• Objections and answers. Each objection point in a sentence, how the filer answered, and whether the answer closed it.
• Timeline. Submission date, dates of each objection and response, and disposition date, so you can see the time from submission to disposition and where it went.

Over several filings, patterns emerge: which questions a department asks repeatedly, which kinds of support it accepts, and how long similar filings tend to take.

Cautions

Access is uneven

Public availability varies by state and by filing, and so does timing. A filing you cannot find may exist but not be public yet. Do not draw conclusions from absence.

Confidential material is withheld

Filers can request confidential or trade-secret treatment for parts of a filing, such as models, proprietary data or detailed underwriting material, and states that grant it withhold those portions. A public filing may therefore show conclusions without the full analysis behind them.

Do not copy rates or forms

Use competitor filings to understand practice and review expectations, not as a source of rates, relativities or form language to reuse. Your rates need to rest on your own experience and analysis, and policy forms may be proprietary or copyrighted.

Context, not support

Another carrier's approved filing shows what one reviewer accepted for one company at one time. It is not, by itself, support for your selections. If you refer to competitor or industry information in your own filing, explain why it is relevant to your book and pair it with your own data and analysis.

A simple routine

Before preparing a rate filing, pull three to five recent filings for the same state and line, read the filing description, disposition and correspondence first, then go into the schedules and supporting documentation for the parts that match what you plan to change. Record the summary above for each. Then read your own draft with the objections you found in mind; our post on why rate filings draw objections lists the most common ones and how to pre-empt them.