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State insurance departments regulate three things insurers file: the rates they charge, the rules that determine how those rates apply, and the policy forms that define coverage. A filing is classified by which of these it changes. The classification decides who reviews it, what supporting material is expected and, in many states, which statutory review standard and timeline applies.
Definitions
Rate, rule and form filings
The price
Rate filing
- Base rates, rating factors and relativities, minimum premiums and loss cost multipliers
- Supported by an actuarial memorandum and exhibits
- Judged against the state's rate standards
- Rate pages go on the Rate/Rule Schedule
How rates apply
Rule filing
- Eligibility, classification, territory, discount, surcharge, fee and cancellation rules
- Can move premium even when no rate number changes
- Many states expect any premium effect to be shown
- Rule pages go on the Rate/Rule Schedule
The contract
Form filing
- Policy forms, endorsements, declarations pages, applications, notices and disclosures
- Review confirms required provisions are present and prohibited ones absent
- Supported by an explanatory memorandum and, for revisions, a redline
- Forms go on the Form Schedule
Rate filing
A rate filing establishes or changes the prices an insurer charges: base rates, rating factors and relativities, minimum premiums, and the multipliers an insurer applies to advisory organization loss costs. The NAIC's model rating laws describe the filed rate material as every manual, minimum premium, class rate, rating schedule or rating plan, and every other rating rule, together with the supporting information behind it.
Rate filings are usually supported by an actuarial memorandum and exhibits: experience, loss development, trend, expense provisions, the overall indication and the selected change, and the impact on policyholders. Rate standards in state law, typically that rates not be excessive, inadequate or unfairly discriminatory, are applied to this filing type. See Actuarial memorandum and Rate filing exhibits.
Rule filing
A rule filing changes the manual rules that govern how rates are applied, without necessarily changing the rate values themselves: eligibility and classification rules, territory definitions, discount and surcharge criteria, installment and policy fee rules, cancellation and minimum premium rules, and similar manual text. Some states also require underwriting rules or guidelines to be filed, or treat certain underwriting criteria as rating rules.
Rule changes often move premium even when no rate number changes, for example by reclassifying risks or tightening a discount's eligibility. Many states therefore expect rule filings with a premium effect to show that effect and may review them like rate filings. Advisory organizations file rules for their members in the same way they file loss costs; see Advisory organizations and loss costs.
Form filing
A form filing establishes or changes the contract language: policy forms, endorsements, declarations pages, applications, and the notices and disclosures used with them. The NAIC's handbook describes form review as confirming that required provisions are present, prohibited provisions are absent and the product meets the state's definition of the line, including any readability requirements. Form filings are usually supported by an explanatory memorandum and, for revisions, a redline or side-by-side comparison with the forms being replaced. See Form filings.
Combination filing
A combination filing changes more than one of these at once, such as a new endorsement and the rate and rule that price it, or a new program with forms, a rating manual and rates. Where a state allows combination filings, filing them together keeps the coverage and its price under a single review and effective date. The NAIC's handbook notes that form reviewers may need to coordinate with rate reviewers so that related rate, rule and form changes take effect consistently.
How filing types appear in SERFF
In SERFF, the filer selects a filing type when creating the filing. Each state configures which filing types it accepts; the common set covers rate, rule and form filings and their combinations, and some states add types for specific purposes such as loss cost adoptions or withdrawals. The filing type controls which schedules are required:
- forms go on the Form Schedule, each listed and attached separately with form number and edition date;
- rate and rule pages go on the Rate/Rule Schedule, with company rate information fields completed for rate changes;
- memoranda, exhibits, checklists and certifications go on Supporting Documentation.
States enforce these placements. New York's SERFF guidelines, for example, say a form schedule must be completed for all form filings, the rate/rule schedule must be completed for rate and rating rule filings, and filings with attachments on the wrong schedule will be rejected.
Type of insurance codes and the Product Coding Matrix
Every SERFF filing is coded with a type of insurance (TOI) and a sub-type of insurance (sub-TOI) from the NAIC's uniform Product Coding Matrix (PCM). There are two matrices, one for property and casualty and one for life, accident and health, annuity and credit. The PCMs are reviewed annually, and any updates take effect January 1.
The property and casualty matrix uses a two-level code:
- TOI is a line-level code such as 04.0 Homeowners, 16.0 Workers Compensation, 19.0 Personal Auto or 20.0 Commercial Auto.
- Sub-TOI is a four-decimal code within the TOI. Under 04.0 Homeowners, for example, the matrix lists 04.0001 Condominium Homeowners, 04.0003 Owner Occupied Homeowners and 04.0004 Tenant Homeowners.
The matrix also maps each code to an NAIC annual statement line, which ties product filings to the line insurers report financially.
SERFF limits each filing to a single TOI and sub-TOI. When one filing covers more than one sub-TOI in the same TOI, the matrix directs filers to the ".0000" combinations code: a homeowners filing that changes both owner-occupied and tenant programs uses 04.0000 Homeowners Sub-TOI Combinations. Some TOIs carry structure in the code itself: other liability and medical malpractice have separate TOIs for occurrence, claims-made, and combined occurrence/claims-made coverage, and the auto codes distinguish private passenger from commercial and liability from no-fault or personal injury protection.
Two practical consequences follow. Filings that span TOIs, such as a package or an interline program, need either separate filings or the TOI the matrix provides for that case. And because codes change over time, research on older filings should account for the matrix in effect when they were filed.
Which kind of filing a change needs
States decide what must be filed for each line and filer, and some lines or commercial risks are exempt from rate or form filing in some states. With that caveat, the usual mapping is:
| Change | Typical filing |
|---|---|
| Overall rate level change, base rate change, new factors for existing variables | Rate |
| Adopting an advisory organization's revised loss costs, or changing the loss cost multiplier | Rate (often a loss cost adoption or reference filing) |
| New rating variable, new tier structure, revised territory definitions | Rate and rule |
| Revised eligibility, classification, fee or cancellation rules | Rule (with premium impact shown if any) |
| New or revised endorsement with no premium effect | Form |
| New or revised endorsement with a premium charge or credit | Form, rate and rule, as a combination filing or linked filings |
| New program or product | Form, rate and rule |
| Withdrawing a product, form or rate | Withdrawal, or the filing type the state designates |
The edge cases are where filings go wrong. A form change that narrows coverage may carry an implied rate effect a reviewer will ask about. A rule change described as administrative may move a measurable share of premium. A filing that adopts advisory loss costs but deviates from them must explain the deviation. In each case, the safer reading is the one that gives the reviewer the rate support or the form language they will otherwise request in an objection.
Before choosing a filing type
- Confirm which filing types the state accepts for the TOI, and whether combination filings are allowed or required, in the state's SERFF General Instructions and Filing Rules.
- Check whether related rate, rule and form changes must share an effective date or be cross-referenced by SERFF tracking number.
- Check whether the line, or the risk size, is exempt from rate or form filing in that state.
- Pick the sub-TOI that matches every program in the filing, falling back to the combinations code when the filing spans several.
State filing requirements and checklists covers how to assemble the full requirement list for the filing type you choose.
Sources
- NAIC, Product Filing Review Handbook (2024)
- NAIC, Uniform Property & Casualty Product Coding Matrix (effective January 1, 2026)
- NAIC, Property and Casualty Model Rating Law (Prior Approval Version), GL-1780
- New York DFS, General SERFF Guidelines for Rate, Form, Territory, Classification and Rule Filings
General information about regulatory practice, not legal or actuarial advice. Requirements differ by state, line and filing; check the current rules with the department of insurance before you file.