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Homeowners Insurance in Alabama November 7, 2011 Alabama Department of Insurance Commissioner Jim L. Ridling.

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1 Homeowners Insurance in Alabama November 7, 2011 Alabama Department of Insurance Commissioner Jim L. Ridling

2 Alabama Department of Insurance Our mission is to serve the people of Alabama by regulating the insurance industry, providing consumer protection, promoting market stability, and enforcing fire safety standards and laws

3 Alabama Department of Insurance Licenses insurance producers (agents) and agencies Licenses insurance companies and pre-need providers Examines insurance companies for financial solvency and market conduct Provides consumer protection and assistance

4 Alabama Department of Insurance Fiscal year budget: $16.6 million – Tax generating agency – Funded through fees collected (licensing fees, primarily) 150 employees – 100 in Montgomery – 25 field examiners – 25 deputy fire marshals

5 The DOI Perspective Despite the tragedy of April 27, the homeowners insurance market remains relatively vibrant in 65 of the states 67 counties Homeowners insurance remains readily available despite the decision of a company to non-renew a segment of its business

6 The DOI Perspective The problems in Alabamas coastal counties have endured for a variety of reasons – Subsequent storms in coastal areas: Rita, Ike, etc. – Expected increase in tropical activity – Economic downturn

7 The DOI Perspective In the balance of the state, the DOI is not receiving significant numbers complaints from consumers regarding access to insurance – Some complaints regarding the loss of coverage from a single carrier, but not widespread – The Department believes the issues will be overcome as carriers contemplate Alabama as a marketplace

8 Definition of Insurance Insurance is defined as the equitable transfer of the risk of a loss, from one entity to another, in exchange for payment. Insurance involves pooling funds from many similar insured entities to pay for the losses that some insureds may incur: Law of Large Numbers says that the predicted losses for the pooled insureds will be similar to the actual losses.

9 INDUSTRY HOMEOWNERS RESULTS Weve defined the Homeowners problem from the coastal consumers perspective. Now lets look at it from the insurers perspective. Over the 7 years : – Insurance companies in Alabama have paid out approximately $117 for Homeowners claims and operating expenses for every $100 of premiums they have collected; – Insurance companies Countrywide paid out approximately $97 for every $100 they collected.

10 INSURERS REQUIRE CAPITAL Based on the law of large numbers, the premium collected should be sufficient, on average over many years, to cover the losses incurred. However, in any given year, there is roughly a 50% chance that losses will exceed the portion of premium collected to pay for those losses. Therefore, insurers must maintain capital over and above the premium they collect in order to be certain they can pay all claims.

11 INSURERS REQUIRE CAPITAL Typically, insurers maintain as much additional capital as they collect in premiums in order to be assured they can cover claims in the most adverse years. (Premium-to- surplus ratio = 1.0) Where do insurers obtain this additional capital? From investors. What do investors require from insurers in return for loaning them this additional capital? Investment income. Whats a reasonable rate of return for investors to make on this capital loan? 11%?

12 INSURANCE INDUSTRY RESULTS Return on Net Worth for : – Property/Casualty Industry = 7.3% – Avg. of 227 other industries = 10.7% – P/C Industry ranked 163 out of 228* industries – P/C Industry ROE was lower than the 227- industry average for 18 of the 20 years * # of industries in S&Ps COMPUSTAT database for which 20 years of data was available.

13 INSURANCE INDUSTRY RESULTS Return on Net Worth for : – Property/Casualty Industry = 6.3% – Avg. of 301 other industries = 9.4% – P/C Industry ranked 200 out of 302* industries – P/C Industry ROE was lower than the 301- industry average for all 10 years * # of industries in S&Ps COMPUSTAT database for which 10 years of data was available.

14 INDUSTRY HOMEOWNERS RESULTS Homeowners Return on Net Worth: Louisiana -32% Mississippi -29% Missouri -12% Kentucky -9% Alabama -8% Arkansas -7% Georgia -7% Nebraska -7% Tennessee -5% Texas -2% Oklahoma -2% Florida 0% W. Virginia +5% Virginia +10% N. Carolina +15% S. Carolina +21% Countrywide +5%

15 INDUSTRY ROE BY LINE OF BUSINESS ALCW P.P. Auto9%7% W.C.8%6% C. Auto3%8% CMP3%8% H.O. -8%5% F.O. -17%5% TOTAL3%7%

16 INDUSTRY HOMEOWNERS RESULTS Alabamas -8% average Homeowners ROE over the last 10 years means that if a company had started with $1 billion in net worth 10 years ago, today the company would only have $434 million net worth remaining. Companies must deploy their capital / net worth where they can achieve a reasonable return for their investors. Clearly a -8% average ROE does not make Alabama an attractive investment for companies. On the Coast, approximately 70% - 80% of the Homeowners policy premium is required to cover wind losses. Upstate it is only about 20% - 35%. A companys Homeowners ROE can be improved in several ways: – Raise rates – Reduce the companys exposure to loss by raising deductibles or excluding wind coverage – Shift to writing more policies Upstate and fewer policies on the Coast – Focus their coastal writings on homes that have been fortified; Improve building codes to lower the damageability of houses; retrofit homes to higher building standards

17 INDUSTRY HOMEOWNERS RESULTS Companies must feel confident that over the long run they can make a profit on Homeowners insurance in Alabama, or they will choose not to offer insurance in our state and utilize their capital to write more business in other states. The Dept. of Insurance permits companies to establish rates that over the long run should generate a profit margin on premiums of approximately 6% (which translates to less than 7% ROE, which is approximately the industrys 2009 countrywide average). Despite that, insurers have not achieved those profit levels. If the Dept. of Insurance were to arbitrarily suppress rates that companies could charge, companies would further reduce their writings in Alabama, thus exacerbating the availability (and thus affordability) of Homeowners insurance.

18 RATING AGENCIES Insurers are rated by A.M. Best for their claims-paying ability, and by S&P, Fitch, and others as to their debt security. Lower ratings by these agencies either drives down the marketability of their products or drives up the cost of their debt. Pressure by these rating agencies may drive insurers to raise rates or reduce their exposure to losses so as to maintain a better rating.

19 ALABAMA RATE STATUTES All Homeowners rate filings from admitted insurance companies require prior approval by the Department of Insurance. Non-admitted (Surplus Lines) companies are not required to file their rates with the Department and the Department has no regulatory authority over their rates.

20 ALABAMA RATE STATUTES Alabama statute says that rates must not be: * Excessive * Inadequate * Unfairly discriminatory

21 ALABAMA RATE STATUTES Not excessive: We require that rates are actuarially justified, meaning the rates do not exceed those rates statistically justified by the insurance companys claim history or models. Not inadequate: We do permit insurance companies to utilize rates below their actuarially justified rates in order to be competitive, as long as it does not endanger the companys financial solvency.

22 ALABAMA RATE STATUTES Not unfairly discriminatory: We review each companys rate structure to ensure that rates are not excessive for any individual territory, policy type, policy limit, deductible level, etc., separately for wind versus non-wind coverage.

23 WHAT MAKES UP THE HOMEOWNERS PREMIUM DOLLAR? In general, the breakdown in Homeowners premium might be as follows: Coastal Upstate Claims Payments = 23% 58% Reinsurance = 40% 5% Claims Adjusting Expense = 10% 10% Marketing Expense = 19% 19% Overhead Expense = 5% 5% Taxes, Licenses, Fees = 3% 3% Total = 100% 100%

24 WHAT MAKES UP THE HOMEOWNERS PREMIUM DOLLAR? For 2009, the breakdown in Homeowners premium statewide for Alabama was as follows: Claims Payments = 96% of direct earned premium* Claims Adjusting Expense = 15% Marketing Expense = 19% Overhead Expense = 5% Taxes, Licenses, Fees = 3% Total = 138% Investment Gain = 4% ROE = -24% * Before reinsurance

25 HOMEOWNERS RATE COMPONENTS Most Companies publish a single combined Homeowners rate to cover all perils insured against. However, in providing justification for those rates, their data is segregated into non- wind and wind components by territory, and the Department of Insurance scrutinizes that justification.

26 HOMEOWNERS RATE COMPONENTS The non-wind portion of a companys Homeowners rates must be justified by the companys Alabama non-wind claims experience statewide and by territory over the past 5 years. For competitive reasons, for some or all territories, companies may choose to file for lower non-wind rates than those justified actuarially, and we generally permit this.

27 HOMEOWNERS RATE COMPONENTS The wind portion of a companys Homeowners rates consists of three components: – The hurricane rate – The non-hurricane wind rate – The cost of reinsurance

28 HOMEOWNERS RATE COMPONENTS The hurricane rate is almost always developed from independent vendors computer models that predict the frequency and severity of hurricanes. The models estimate the average annual claims that the company will experience based on the policies they currently write in the state. These claim estimates are developed at the zip code level and then aggregated for each rating territory used by the company.

29 HURRICANE MODELS Why are hurricane models used instead of actual hurricane experience? The significant variation in the frequency of different magnitudes of hurricanes diminishes the accuracy of historical hurricane loss experience for projecting expected loss levels for the policies to which proposed rates will apply. Average expected recurrence periods for the larger, more severe storms are so long that many external variables will change in the time periods between occurrences. For example, the area of southern Florida hit by Hurricane Andrew in 1992 was last hit by a major hurricane, Hurricane Betsy, in The type, number, value, vulnerability and geographical distribution of exposed properties in the area impacted by Hurricane Andrew are very different than those of the exposed properties in Actual loss statistics from a hurricane that occurred many years ago are not easily adjusted for the type, number, value, and vulnerability of present day structures.

30 HURRICANE MODELS Since historical hurricane losses cannot be used to accurately estimate current hurricane loss potential, insurers contract with an outside vendor, AIR or RMS, which use an alternative methodology based on Monte Carlo simulation to arrive at the insurers expected annual hurricane losses. This approach involves the development of computer programs that describe in detail the frequency of hurricanes, their meteorological characteristics, and their effects on exposed properties. A high-speed computer then simulates a large set of hypothetical hurricanes and estimates the resulting property losses based on the insurers exposure. In order to estimate the potential loss from hurricanes, 100,000 scenario years of potential hurricanes are simulated. This large number of simulations attempts to ensure that the resulting probability distribution of losses converges to a stable representative distribution of potential annual hurricane loss (the Law of Large Numbers at work again). The pattern of simulated hurricanes is representative of what has occurred historically because meteorological data on the actual events since 1900 were used to estimate the parameters of the hurricane simulation model. The meteorological sources used to develop the model are the most complete and accurate databases available from various agencies of the National Weather Service and the National Oceanic and Atmospheric Administration (NOAA), including the National Hurricane Center.

31 HURRICANE MODELS The primary characteristics of hurricanes used to simulate each storm and resulting wind speeds are: 1. Hurricane Frequency 2. Landfall Location 3. Central Pressure 4. Radius of Maximum Winds 5. Forward Speed 6. Track Angle at Landfall 7. Storm Track 8. Gradient Wind Reduction Factor 9. Peak Weighting Factor The probability distributions for several of these variables (2-6) are estimated for coastal segments of equal length from Texas to Maine. Random samples are generated from the probability distributions of these input variables to assign values to the variables for each simulated hurricane.

32 HURRICANE MODELS HURRICANE WIND SPEED ESTIMATION Once the key parameters have been generated, the meteorological relationships among them are used to develop a complete time profile of wind speeds for each location affected by the storm. This involves the following calculations for each simulated hurricane: 1. Gradient-Level Wind Speed 2. Adjustment to surface (10-meter) level 3. Storm Asymmetry 4. Storm Decay (Filling) 5. Radial Decay (Storm Center-Relative Wind Speed) 6. Adjustment of Wind Speed for Surface Friction and Averaging Time

33 HURRICANE MODELS DAMAGE ESTIMATION AND DEMAND SURGE Engineers have developed damage functions that describe the interaction between buildings, (including both structural and nonstructural components) and their contents, and the local wind speeds to which they are exposed. These functions relate the mean damage level as well as the variability of damage to wind speed at each location. Because different structural types will experience different degrees of damage, the damage functions vary according to construction class, occupancy, and height. The model estimates a complete distribution around the mean level of damage for each local wind speed and each structural type. Losses are calculated by applying the appropriate damage function to the replacement value of the insured property. The damage functions capture the effects of wind duration as well as the effect of peak wind speed. The longer a property experiences severe wind speeds, the greater the damage. The hurricane damageability relationships incorporate well-documented engineering studies published by wind engineers and other experts. They also incorporate the results of post-hurricane field surveys performed by engineers. These relationships are continually refined and validated based on actual client companies loss data. Any major hurricane event causes an increase in demand for materials and services to repair and rebuild damaged property. This can put pressure on costs, resulting in higher than expected costs. Therefore, models apply aggregate demand surge functions to loss estimates to take into account the combined effects of events clustered in both time and geography.

34 HURRICANE MODELS LOSS CALCULATION The insurer supplies the modeler with a detailed exposure database containing insured values by policy level and ZIP Code for each line of business, construction, and deductible combination. Damage functions relating wind speed and wind duration to the percentage of property damaged for varying types of coverage and construction are used to produce loss estimates by zip code for each simulated hurricane. MODELED LOSS ESTIMATES Losses estimated from 100,000 years of simulated potential hurricanes are summed and divided by 100,000 to produce the expected annual losses from all hurricanes for each ZIP Code. ZIP Code loss estimates are then aggregated to produce expected annual loss by county and state. Hurricane factors are then calculated as the total loss estimate for a given ZIP Code, county, or state divided by the total insured value in thousands of dollars (amount of insurance years). This factor is applied to the expected average amount of insurance years in the determination of the overall rate level indication.

35 HOMEOWNERS RATE COMPONENTS The hurricane computer models are reviewed by a national industry expert panel every time they are revised to ensure that their statistical methodologies are valid. These models are being regularly updated to include new analyses and data (such as climate change and recent storms) that affect the frequency and severity of hurricanes.

36 HURRICANE MODEL MISS Despite the progress made in developing hurricane models, a study of the hurricanes of 2004, 2005 and 2008 show that the models typically under-estimated the losses that those hurricanes would generate for homes and small businesses. The actual storm losses ranged from 84% to 188% of the losses predicted by the models. The average actual- to-predicted ratio was 128%. The error in the model predictions was due to non- modeled perils, poor data quality, and model error.

37 HURRICANE MODEL VIEWS As a result of climate change theories, hurricane modelers have developed two approaches to estimating future hurricane losses. Hurricane frequency changes cyclically, depending on whether we are experiencing a cycle of warm sea surface temperatures (WSST) or cooler sea surface temperatures. These cycles tend to run in 25- year spans on average. The Long-Term View of the models utilizes data from all hurricanes that have ever occurred, regardless of the cycle phase in which they occurred. The Near-Term View only utilizes data from hurricanes that have occurred in a cycle similar to the current cycle we are experiencing (i.e. only warm water cycles or only cold water cycles).

38 HURRICANE MODEL VIEWS The U.S. is currently in a warm sea surface temperature cycle. This cycle tends to produce more hurricanes than the cold water cycle. Most insurers and reinsurers would prefer to use the WSST view of the models, believing this is a better prediction of what will occur next year while we are still in a warm water cycle. The DOI does not permit insurers to use the WSST view, but we cannot prevent the reinsurers from doing so.

39 HOMEOWNERS RATE COMPONENTS The non-hurricane wind rate is developed from either the individual companys 20- or 30-year historical claims data for Alabama or from industry claims data for Alabama. The losses for the 20 years are compared to the premiums for those 20 years to develop a non-hurricane wind load, which is then added to the hurricane load developed from the models. In the case of the April, 2011 Alabama tornadoes, which may be considered a 1-in-250 year event, the DOI has announced that it will only permit 8% of these losses to be included in future rate filings. (8% / 20 years = 0.4% = 1/250).

40 HOMEOWNERS RATE COMPONENTS The cost of reinsurance. Companies cannot risk having to pay the entire loss from a large hurricane or tornado outbreak, so they must purchase reinsurance. Reinsurers use the same hurricane models as the companies, though they may utilize different assumptions, such as the Near-Term version. The rates for reinsurance that are charged to the companies are not regulated by the Dept. of Insurance, and the companies pass this cost on to their insureds in the premiums they charge.

41 COMPONENTS OF THE REINSURANCE COST LOAD If a reinsurer charges an insurer $1M for their Homeowners coastal catastrophe reinsurance coverage, the components of that premium are approximately: Expected Losses = $200,000 Risk Load & Profit = 600,000 Overhead Expense = 200,000 1,000,000

42 REINSURANCE COST Reinsurance is a global industry, so the cost of hurricane reinsurance for most companies is unfortunately impacted by large catastrophes experienced around the world and by the current financial crisis. Over the past 5 years the cost of this wind reinsurance had been rising, but recently it has stabilized and in some cases declined. But with the high cat losses of 2011 (quakes in Japan, New Zealand, Turkey; tornadoes and wildfires in the U.S.), it is not certain yet if reinsurance rates will rise soon.

43 TERRITORIAL RATE DIFFERENCES So what causes rates to vary by territory? – Actual Fire, Water, Theft, Liability claims – Actual non-hurricane wind claims – Hurricane model estimates – Cost of reinsurance – Competition in more desirable (i.e. predictable) territories

44 HOMEOWNERS RATE FILINGS Companies almost never file wind rates below the actuarially justified rates since there is a high risk that the actual wind/hurricane losses could be greater than those predicted by the models, and because of the cost of their reinsurance. Companies are typically justifying rate increases in the 10% - 20% range due to higher losses, prior indicated increases that they did not request, inflation, and increases in hurricane model estimates. The DOI has not been permitting any individual insured to receive more than a 35% increase at renewal, assuming no change in coverage.

45 HOMEOWNERS RATE FILING REVIEWS Though Alabama Homeowners rates are very high on the coast, the DOI is scrutinizing every admitted companys rates to make certain that they are statistically justified and that they will not generate excessive profits for the companies in the long run.


47 ALABAMA HOMEOWNERS RATES STATE PREMIUM INDEX TO AL CW $718 76% ID $397 42% AL % IL % AK % IN % AZ % IA % AR % KS % CA % KY % CO % LA 1, % CT % ME % DE % MD % DC % MA % FL 1, % MI % GA % MN % HI % MS 1, % Gulf Coast – Averages 41% above AL Tornado Alley – Averages 5% below AL Eastern Seaboard – Averages 29% below AL

48 ALABAMA HOMEOWNERS RATES STATE PREMIUM INDEX TO AL MO $716 76% PA $607 64% MT % RI % NE % SC % NV % SD % NH % TN % NJ % TX 1, % NM % UT % NY % VT % NC % VA % ND % WA % OH % WV % OK 1, % WI % OR % WY % Gulf Coast Tornado Alley Eastern Seaboard

49 ALABAMA HOMEOWNERS RATES Average premium relativity for 3 large companies for a $200,000 home compared to Muscle Shoals, AL: Rome, GA = 78% Pittsburg, KS = 98% Russellville, AR = 99% Muscle Shoals, AL = 100% Beatrice, NE = 105% Farmersville, LA = 116% Walls, MS = 127% Joplin, MO = 129% Brownsville, TN = 135% Mt. Pleasant, TX = 164% Miami, OK = 171% Ft. Walton Beach, FL = 214%

50 ALABAMA HOMEOWNERS RATES Average Premium Relativity (with Wind) by City for a $200,000 Home: Birmingham (35242) = 100% Huntsville (35801) = 110% Montgomery (36117) = 111% Tuscaloosa (35401) = 120% Camden (36726) = 135% Gadsden (35901) = 136% Dothan (36301) = 139% Saraland (36571) = 263% Mobile (36608) = 294% Bay Minette (36507) = 300% Fairhope (36532) = 311% Gulf Shores (36542) = 328%

51 REGULATION OF HOMEOWNERS RATE FILINGS Current rate filing environment: Prior Approval by the DOI – our current law All filings reviewed by an actuary for justification We have for the most part pursued an open market philosophy, not arbitrarily suppressing rates, so as to not discourage insurers from writing in Alabama

52 REGULATION OF HOMEOWNERS RATE FILINGS Steps Taken by DOI to Help Coastal Consumers With Their Homeowners Costs: Capped profit margins built into the rates at 6% Disallowed an expense load for the cost of capital despite such load being a reasonable financial concept Disallowed the use of near-term (warm water) hurricane models Required statistical justification by territory for all rate changes, then limited carriers requested rate increases on the coast below those increases that were justified Disallowed an expense load for cost of reinsurance with affiliates Disallowed premium surcharges for claims caused by Acts of God Disallowed carriers from raising rates more than once a year, despite statistical justification to do so Capped individual consumers rate increase at 35% annually even though larger increases were justified

53 REGULATION OF HOMEOWNERS RATE FILINGS Alternative rate filing environments: File and Use – File rate change and implement it after 30 days if the DOI doesnt object first Use and File – Implement rate change, then file it with the DOI 30 days later, at which time the DOI can object Informational Filings Only – DOI cannot object ever Prior Approval combined with a Flex Band – If the rate increase is less than 10%, the DOI cannot object

54 REGULATION OF HOMEOWNERS RATE FILINGS Alternative rate filing environments: Generally the DOI only permits an insurer to make one rate filing every 12 months. It has been suggested that it would attract new insurers to our state if we would permit multiple filings in a year under a Prior Approval / Flex Band environment. Additional filing restrictions would be required to prevent an insured from receiving large increases at renewal.

55 HOMEOWNERS DEDUCTIBLES Insurers are permitted to require minimum hurricane/named storm/wind deductibles of 5% near the coast, 2% in the remainder of Mobile & Baldwin Counties, and ½% in the remainder of state. Some insurers also offer a 10% hurricane/wind deductible. Minimum deductibles for All Other Perils (AOP) tend to be $500 or $1,000, with optional AOP deductibles up to $2,500 or $5,000. Some insurers are now also offering AOP deductibles of ½% or 1% with a $1,000 minimum. Insurers are permitted to exclude wind coverage completely in the AIUA rating territories in Mobile & Baldwin Counties. The DOI requires insurers to justify the rates and credits that they use for these deductibles and wind exclusions.

56 HOMEOWNERS DEDUCTIBLES Many consumers that are required to carry large % wind deductibles are functionally uninsured, meaning they are not able financially to actually pay for repairs within their deductible, so damage goes unrepaired. In Hurricane Ivan, approximately 90% of all hurricane claims were less than a 20% deductible. One option that has been discussed is to permit insurers to sell larger wind deductibles, even up to 15% and 20% deductibles, and have the State offer low interest loans to consumers to repair the damage within the deductible when a storm occurs. The consumer would receive a premium discount of approximately 30% for a 20% deductible compared to the premium for a 5% deductible: a savings of perhaps $1,000 per year. Also, reinsurers would likely lower their charges to the AIUA and other insurers if more consumers carried a 20% wind deductible, thus helping lower rates further.

57 AIUA The purpose of the AIUA is to provide a market wherein owners of eligible property located in coastal areas of Baldwin and Mobile counties may obtain essential insurance when they are unable to obtain coverage in the private insurance market. AIUA is owned and managed by the property- writing insurers of Alabama. Any losses in excess of premiums collected are the responsibility of the member insurers.

58 AIUA By design, AIUA policies provide basic, no frills, coverage at actuarially sound rates. Typically, a property owner will seek an AIUA policy as a "last resort" because they have been unable to find better coverage at lower rates elsewhere. An insurers participation in the AIUA is determined, generally, by the percentage of market share the company writes in coastal areas of Baldwin and Mobile compared to the percentage of market share that the company writes in the entire State. A Company that voluntarily writes their share (or more) in the coastal areas (as compared to their state-wide market share) will generally have a smaller percentage or no share of participation in the AIUA.

59 AIUA COVERAGE The Alabama Insurance Underwriting Association provides two types of policies: – Fire and Extended Coverage policy (which includes Fire, Lightning, Explosion, Smoke, Riot and Civil Commotion, Damage from Aircraft and Vehicle Accidents, Windstorm, Hail, Vandalism and Malicious Mischief). – A Wind and Hail only policy (written with a package policy issued by an insurance company that underwrites other coverages). – Theft coverage may be added by endorsement. – Policies may be written on an Actual Cash Value (ACV) or Replacement Cost Value (RCV) basis. Only condominiums, homes, mobile homes and commercial businesses located in Zones 1, 2, 3 and 4 of Baldwin and Mobile Counties are eligible in the Plan.

60 AIUA COVERAGE The AIUA offers coverage on the building or structure up to a maximum of $500,000, combined dwelling and contents, for a one to four family residential location. A total limit of $1,000,000, combined building and contents coverage, can be written for a commercial location. A builders risk policy will also be issued for the same limits that qualifies for the Plan. Vacant property, motor vehicles, and farm properties are ineligible for coverage.

61 AIUA Rates AIUA recently adopted RMS model 11.0, and reduced wind rates approx. 15% in Zones 2, 3 and 4 but raised rates 11% in Zone 1. Average ratio of AIUA rates to private industry rates, after adjusting for coverage differences: * Zone 1 = +43% * Zone 3 = +22% * Zone 2 = -15% * Zone 4 = -20%

62 AIUA WRITE-OUT CREDITS ZONE 1: Credit for voluntary writings shall be calculated on the basis of 125% for Fire policies, 100% for Homeowners and Mobile Homeowners policies, and 75% for Commercial Multi-Peril policies. ZONE 2: Credit for voluntary writings shall be calculated on the basis of 100% for Fire policies, 75% for Homeowners and Mobile Homeowners policies, and 50% for Commercial Multi-Peril policies

63 AIUA WRITE-OUT CREDITS ZONE 3: Credit for voluntary writings shall be calculated on the basis of 75% for Fire policies, 50% for Homeowners and Mobile Homeowners policies, and 37.5% for Commercial Multi-Peril policies. ZONE 4: Credit for voluntary writings shall be calculated on the basis of 50% for Fire policies, 37.5% for Homeowners and Mobile Homeowners policies, and 25% for Commercial Multi-Peril policies. Premiums for policies excluding wind and hail coverage are not eligible for credit. Automobile premiums and Farm premiums are not eligible for credit.

64 AIUA WRITE-OUT CREDITS Of 485 insurers licensed to write property in AL, 329 are exempt from participation: – 306 insurers write no P&C premium in AL – 156 insurers are subject to assessments ranging from.0001% to 19.6% – 69 insurers reported voluntary written premiums for credits – Of those 69 insurers, 23 wrote enough voluntary premiums to be exempt from AIUA assessments

65 AIUA PROFILES As of Sept. 2011: 2009 PIF WP TIV Mkt. Sh. Zone 14,963 $16.6M $0.9B52% Zone 25, M 1.1B11% Zone 34, M 0.7B 4% Zone 47, M 1.3B 3% Total 22, M 4.0B 10% Proj , M 4.7B

66 COASTAL STATES WIND POOL PROFILES PIF TIV Mkt. Share TX 246,000 $68.5B 4.4% LA 119, B 8.1% MS 46, B 5.9% SC 47, B 4.9% NC 245, B9.9% FL 1,460, B 16.9% AL 23, B1.9%

67 AIUA REINSURANCE Layer 5: Retained Excess of $400M Layer 4: $150M xs $250M = $400M : 140 Yrs Layer 3: $100M xs $150M = $250M : 81 Yrs Layer 2: $50M xs $100M = $150M : 49 Yrs Layer 1: Retained $100M : 33 Yrs Total annual reinsurance cost is approx. $18M (without reinstatements) of the $45M anticipated written premium.

68 COASTAL STATES WIND POOL REINSURANCE RETENTION LIMIT $Yrs $ Yrs TX 1.6B28 2.2B 40 LA 100M N/A 500M N/A MS 15M N/A 779M 110 SC 10M 5 1.5B 200 NC 1.3B B 134 AL 100M M 140

69 COASTAL STATES WIND POOL RECOUPMENT CAPABILITY AL: Levy assessment on all property writers. Insurers can only recoup in rate filings. LA: Policyholders of all property writers are assessed; can take credit on state income tax. MS: Policyholders of all property writers are assessed. FL: Policyholders and insurers are assessed. TX: No Wind Pool direct assessment on policyholders, only insurers. FAIR Plan assessments can be passed on to policyholders.

70 AIUA EXCESS LOSSES If the AIUA experiences losses in excess of the funds it has on hand, or in excess of its reinsurance treaty, then it can either: – assess all participating insurers for the needed funds, or – issue bonds to obtain the funds immediately, then assess the insurers annually for the cost to service those bonds.

71 CATASTROPHE FUND It has been suggested that a state or regional Catastrophe Fund be created to provide reinsurance at a discounted rate to the AIUA and other insurers (e.g. captives) so as to lower the premiums charged to consumers. The FLA Cat Fund is an example of this. The Cat Fund could be a non-profit, and thus not require the sizeable risk/profit loads that reinsurers charge. The Cat Fund could cover multiple states, either contiguous or more remote, in order to obtain spread of risk, and thus hopefully earn a lower rate from reinsurers than just a statewide fund.

72 CATASTROPHE FUND The Cat Fund would need some initial capital: – State or County seed money – LOC from some source – Issue bonds The Cat Fund would charge insurers a reinsurance premium, which would build the capital base in non-storm years.

73 WHAT ARE CAPTIVES? A captive is a single-state authorized insurer. Types of captives: – Pure captive: A company that insures risks of its parent, affiliates, or controlled non-affiliates. – Association captive: Any company that insures risks of association members & their affiliates. – Sponsored captive: Any captive whose minimum capital/surplus is provided by one or more sponsors to insure the risks of separate participants. – Protected cell: A separate asset account established by a sponsored captive. – A captive may be formed as a stock corporation, a mutual corporation, or a reciprocal.

74 AN 831(b) CAPTIVE A captive or protected cell may elect to be an 831(b) insurer for federal tax purposes: – Federal income tax only levied on investment income, not underwriting profit. This allows you to grow your capital base quickly in non-storm years. – Maximum annual written premium permitted in the cell is $1.2M (at $3,000 premium per policy, max of about 400 insureds; perhaps one cell per town; fortified homes only) – Each cell must have a substantially different ownership and its own capital – All of the cells could enter into a pooling reinsurance agreement so as to get spread of risk

75 BENEFITS OF A CAPTIVE Purpose/advantages of a captive: – To insure availability of a coverage at a price not offered in the marketplace. Rates can exclude a profit load, but must include interest payable to provider of capital. – To gain control over underwriting or claims handling – To offer flexibility in coverages and deductibles – To share in any long-term earnings – Premium tax only 0.4%

76 DISADVANTAGES OF A CAPTIVE Lack of spread of risk Lack of access to Guaranty Fund Possible lack of reinsurance availability due to risk characteristics Possible capital calls or premium assessments required to cover extreme losses, especially in the early years after formation. Will captive members have the financial wherewithal to respond? Mortgage companies may not accept a captive as your insurer

77 CAPITAL REQUIREMENTS FOR A SPONSORED COASTAL CAPTIVE Capital required for a sponsored captive is $500,000 in cash, LOC, or high quality securities. Each cell must have capital sufficient to cover more than its expected losses per actuarial feasibility study. Required surplus > 10 times largest single net exposure insured. Surplus must be > 20% of loss reserves. Surplus must be > 33% of net written premium Cell insureds may be required to provide some capital.

78 OTHER ISSUES FOR A SPONSORED COASTAL CAPTIVE Must hire a TPA to handle underwriting, claims, administration, legal, accounting, auditing, actuarial for each cell. This includes an agreement for access to cat loss adjusters. Each cell must have its own Board, its own reinsurance, its own capital/surplus.

79 MITIGATION OF HOMES The loss portion of Homeowners, the pure premium = loss frequency times loss severity. On the coast, approx. 75% of premium is to cover wind losses, and consumers cannot affect the frequency of the wind. Therefore, to lower premiums for the long term, one must lower loss severity. 2 ways to do that: – Higher deductibles – Reduce homes vulnerability to wind

80 MITIGATION OF HOMES To reduce your vulnerability to wind, retrofit your home to IBHS Bronze, Silver or Gold standard. Cost to retrofit to Gold approx. $10,000? – Annual premium savings from discounts is 35% of your wind premium….perhaps $1,000? – With a matching grant, thats a 5-year payback period. – Probably means you dont have to find alternate housing while repairs are made – Could save your life! – Should increase the market value of your house at resale; make it more attractive to buyers – As more consumers do it, improves resiliency of your town

81 BUILDING CODES Change municipal/county codes to build stronger homes Toughen home inspections; hire more trained inspectors Insurers will compete for fortified / mitigated homes Reinsurers will take note and should lower reinsurance costs

82 Taxes on Insurance in Alabama For admitted carriers, the base tax rate is 3.6 percent – one of the nations highest (1.0 percent for low value dwellings and residences in Fire Protection Classes 9 and 10) – A credit of up to 1.0 percent is allowed for offices in the state – A credit of up to 1.0 percent is allowed for real property investments – 38 companies (not all homeowners companies) took credits in – 1 company took the full 2.0 percent credit in 2010.

83 Taxes on Insurance in Alabama Premium Taxes expected to generate $ million in – This includes a one-time $10 million payment – Premium tax collections have been flat or falling since the economic downturn – Approximately 90 percent of the insurance premium tax goes to the General Fund. The remainder goes to the Education TF and the Mental Health Fund. – The DOI keeps no tax proceeds

84 Taxes on Insurance in Alabama For the non-admitted market, the tax rate is 6.0 percent – again, one of the nations highest – The tax is shown on the declarations page, unlike the admitted market where the tax is imbedded in the rate – The tax is collected from the broker (agent) rather than the company

85 Taxes on Insurance in Alabama Surplus lines taxes collected in 2010: $187 million Taxes collected from brokers in Mobile/Baldwin counties: $109 million

86 New Markets in Alabama In the past year, three new companies (two surplus lines and one admitted) have entered the coastal insurance market. In 2010 and 2011, the DOI has attended with Florida Insurance Summit, where dozens of property insurers meet to discuss current trends. The DOI has met with approximately 20 companies to attempt to expand new markets

87 Consumer Issues The Department takes its consumer protection role seriously, helping Alabamians every day with insurance issues Available for town meetings, provide literature and assistance to consumers While the coastal market is difficult, Alabama is similarly situated to other coastal states, particularly those on the Gulf Coast

88 Consumer issues There have been several bills introduced in recent years to address consumer concerns. Many of these bills have been supported conceptually or specifically by the Department of Insurance

89 Role of Government in Rate Approval Alabama law requires insurers to file proposed rates with DOI – Law requires DOI to respond within 30 days or the request is deemed approved – Questions from DOI restarts the 30-day clock – Many states have flex rating or file and use laws – Alabamas law is more restrictive than most – Section RATES Not excessive, not inadequate, and not unfairly discriminatory

90 Bill of Rights Mississippi has done this more as a checklist of the items in a policy – Does not override what is in the policy – Serves as an outline as to whats in the policy

91 Declarations Page Transparency Bill previously introduced sought cost per thousand for wind, catastrophic wind, fire, theft, liability, flood, and others Issues: – Flood is not in policy – Smaller companies do not break out cost to that depth DOI Perspective: Supports actual cost of wind, catastrophic wind and all other perils on declarations page

92 Clarity The bill introduced last year sought to require insurers to provide data going forward on premiums and losses in several peril categories by county and ZIP code The bill also would require premium and loss data by county and ZIP code dating back to DOI perspective: Room for a compromise going forward

93 Parity Bills have been introduced in the past to force rate parity: – Equivalent rates in fire classes – No more than 1.5 times rate within fire classes – No more than 2 times rate within fire classes DOI perspective: A highly questionable strategy that would put the states market in danger

94 Questions

95 APPENDIX: DETAILED HOMEOWNERS RATE REVIEW OUTLINE Insurance Departments Charge Regarding Rates Alabama statute requires filed rates to not be excessive (that is, they must be actuarially justified), inadequate (to the point that insufficient premium could lead to a companys insolvency), or unfairly discriminatory (ensuring that rates are not excessive for any individual territory, policy type, coverage, etc.). The Department therefore reviews all Homeowners rate filings to ensure compliance. General Outline of Procedure When an insurance company makes a filing to revise their Homeowners rates, they are required to provide 5 years of premium and loss data on a statewide basis to develop their statewide rate change indication. The premiums and losses from those 5 years need to be adjusted so as to be representative of the premiums and losses that would be generated in the upcoming 12 months after the rate change effective date. The companys projected overhead expenses for the coming year are added to the projected losses, the sum of which is compared to the projected premiums to see if the projected premiums are sufficient or deficient to allow the insurance company to make a 6% profit. Premium Adjustments The premiums collected by the company over the past 5 years need to be adjusted so as to be a good proxy for the expected premiums for the upcoming year. There are two adjustments required. Adjust premiums to current rate level. The company has most likely taken some rate increases or decreases over the past 5 years, and these changes must be taken into consideration. To test the current rate structure, all of the policies written in the last 5 years must have their premiums recomputed using the rates the company is currently charging. Some companies have sophisticated computer systems that can rerate all policies from the last 5 years at todays rates so as to accomplish this adjustment, and this is the most accurate way to accomplish this. Most companies, however, do not have this capability, so a standard, approved mathematical formula is used to make this adjustment. These calculations must be provided to the Department for verification. Adjust premiums for premium trend. Over the years a companys policy profile will undergo coverage changes such as change in the average amount of insurance, deductible mix, territorial mix, construction mix, protection class mix, and other endorsement changes. Past years premiums must be adjusted to reflect this change from the past and into next year. These calculations must be provided to the Department for verification. Applying these two adjustments to the actual collected premium yields trended earned premiums at current rates that can be used to calculate a loss ratio (which is the projected losses divided by projected premiums) for each year.

96 DETAILED HOMEOWNERS RATE REVIEW OUTLINE Loss Adjustments Losses will typically be separated into three categories: non-wind losses (such as fire, theft, water, liability), non-catastrophe wind losses (wind losses not attributed to a hurricane or tornado), and catastrophe losses. Catastrophe losses: Most companies now have access to hurricane/tornado computer models and must provide the models average annual loss (AAL) for their company by territory in Alabama. Many companies will run two different models (from two different model vendors) and take an average of the two models results, or just use the output from one model. Models provide both a long-term result and a near-term result (the latter is currently always higher, as it reflects anticipated greater frequency and severity of storms due to the warmer Atlantic water temperatures). The Department does not currently permit the use of the near-term versions of the models for ratemaking purposes. The Department always asks the company what model they used, verifies which version they used, and verifies what adjustments were made to the model. The Department generally only permits two adjustments to the models: (1) demand surge (reflecting the anticipated increased cost of building materials and labor after a hurricane due to supply shortage), and (2) loss adjustment expense (covers the cost of the claims adjusters handling the claims). On the rare occasion that a company doesnt have access to a model, they usually refer to an Insurance Services Office (ISO) filing and use ISOs hurricane load for Alabama by territory. Non-catastrophe wind losses: Companies will typically calculate the ratio of their non-catastrophe wind losses to non-wind losses for each of the last 20 years and determine an average ratio over the 20-year period, then apply this ratio to their trended ultimate non-wind losses in order to incorporate a non-catastrophe wind load. Some companies may have this ratio generated by a model. The calculation of this load must be provided to the Department in the companys rate filing for verification. Non-wind losses: These losses must be provided for each of the 5 data years being used in the filing. Two adjustments must be made to these losses: (1) trend (i.e. the impact of inflation), and (2) loss development factors to project reported losses to their ultimate, settled level. Trend: The trend factor is intended to bring a past years losses up to the inflationary level the company will experience in the coming year. The calculation of the annual trend factor begins with the average pure premium for a company, which is the total incurred losses (paid losses plus reserves) from all claims for a data year divided by the earned policy counts in that data year. The pure premium may also be calculated as the average claim frequency for the year (claim counts divided by earned policy counts) times the average claim severity for the year (total incurred losses divided by the claims count). Companies will either develop an annual trend factor for the average pure premium per policy, or they will calculate the trend separately for frequency and severity and then multiply those two trends together. Either method is appropriate. To calculate these trends, the company will display their companys frequency, severity, or pure premium for Alabama by quarterly periods for approximately 20 quarters, then fit a statistical curve to the data to calculate the average annual percentage change in the frequency, severity, or pure premium. If the company does not write much business in Alabama (suggesting that their data is not statistically credible), they will need to supplement their own Alabama data with industry Alabama data to develop the annual trend factor. This data and the calculation of the annual trend factor must be provided to the Department for verification. The annual trend factor for Homeowners is usually in the 5% range, not much higher than the annual change in CPI. This annual trend factor is now applied to each of the 5 data years losses. For the oldest year, the losses are increased by the annual trend factor 6 times in order to account for the inflation for the six years from that data year to the year after these new rates go into effect. The second oldest years losses are increased by the annual trend factor 5 times, and so on for the remaining three years of losses. Loss development factors to generate ultimate losses: Reported incurred losses for each of the 5 data years are immature, in that some claims are still not settled and their reserves that are included in incurred losses are often understated. Loss development factors are calculated to project these immature incurred losses to an ultimate settled level, and the calculation of these development factors must be provided to the Department for verification.

97 DETAILED HOMEOWNERS RATE REVIEW OUTLINE. Data Year Loss Ratio For each data year, the company takes the incurred losses that have been multiplied by that years loss trend factor and loss development factor, and divides it by the earned premium that have been multiplied by the rate level factor and the premium trend factor, which yields the trended ultimate loss ratio for each data year. The company then takes a weighted average of these 5 loss ratios using weights of 10%, 15%, 20%, 25%, and 30%, giving the more recent years the greater weight since they should be more representative of what the company can expect to happen next year. This yields the trended ultimate weighted average non-wind loss ratio. If the company computed a non-catastrophe wind factor (discussed above), then this ultimate non-wind loss ratio needs to be multiplied by that factor to arrive at the non-catastrophe ultimate loss ratio. If the company computed a non-catastrophe wind loss ratio, then that loss ratio needs to be added to the non-wind loss ratio. The Department verifies all of these calculations. Credibility: The company now needs to determine how credible this non-catastrophe ultimate loss ratio is. Different companies use different standards based on statistical assumptions, but the more common standard is 40,000 policy counts. They add up the number of policies they wrote over the 5 year experience period, divide that total by 40,000 house years, then take the square root of that result to arrive at the credibility ratio. The Department verifies this calculation. To the degree that the non-catastrophe ultimate loss ratio has a credibility factor less than 100%, then that loss ratio needs to be averaged with the trended permissible loss ratio. Trended Permissible Loss Ratio: To develop the Permissible Loss Ratio, the company first develops its expense ratio, which is the sum of their Commission ratio, General Expense ratio, Other Acquisition ratio, Taxes/Licenses/Fees ratio, and their Profit margin. The company provides an exhibit displaying their actual ratio for each of these component ratios for the last 3 years, and computes the 3-year average of each component ratio. (Commissions can range from 0% to 25% depending on whether they sell through agents or directly on the internet, General Expenses (Overhead) are usually 8-15%, Other Acquisition (Marketing) Expenses are usually 8-15%, Taxes are usually 4-5%, and Profit cannot exceed 6%.) They will then select a ratio for each component and add these to get their Permissible Loss Ratio. Multiplying this Permissible by the annual loss trend factor (discussed above) and dividing it by the annual premium trend factor (discussed above) yields the trended permissible loss ratio. The Department reviews and verifies these calculations. Credibility-Weighted Non-Catastrophe Loss Ratio: This ratio is derived by multiplying the non-catastrophe ultimate loss ratio by the companys credibility factor, then adding to it the product of the trended permissible loss ratio and the complement of credibility (100% minus the credibility factor). The Department verifies this calculation. Loss Adjustment Expense: At this point, assuming loss adjustment expenses were not already included with the original incurred losses, the credibility-weighted non-catastrophe loss ratio needs to be multiplied by the loss adjustment expense factor. The company provides an exhibit showing the calculation of this factor by comparing loss adjustment expenses to losses for the last 3 years or more, and computing an average factor. To this result is now added the companys catastrophe loss ratio (discussed above). Reinsurance Load: Companies must add in a reinsurance load to reflect their net cost of reinsurance. The reinsurance load is computed by subtracting from the companys reinsurance cost (as a percent of premium) what the catastrophe model says the company can expect to recover from their reinsurers if a catastrophe occurs. The company must provide this calculation to the Department for verification. Generally the Department only allows a company to include their reinsurance cost for reinsurance purchased from a non-affiliated reinsurer. This now yields the final adjusted loss ratio. Indicated Rate Change: The indicated rate change is determined by dividing this final adjusted loss ratio by the Permissible Loss Ratio (discussed above), multiplying that result by 100, then subtracting 100%.

98 DETAILED HOMEOWNERS RATE REVIEW OUTLINE Territorial Changes Most companies are not going to change the rates in all territories by the statewide rate indication, but will want to vary the change by territory. To justify the territorial rate changes they must follow these steps: Provide 5 years of earned premiums at current rate level for each territory separately, and for statewide. Provide 5 years of incurred losses (separately for non-wind, non-catastrophe wind, and the model losses for catastrophe) by territory and statewide. Calculate each territorys 5-year loss ratio by dividing the total losses in (2) by the premiums in (1). Also calculate the statewide loss ratio in the same manner. Calculate each territorys loss ratio relativity by dividing each territorys loss ratio in (3) by the statewide loss ratio calculated in (3). Multiply each territorys relativity in (4) by the statewide rate level indication derived above to yield the indicated territory rate change. The Department does not permit companies to raise any territorys rates by more than the territorys indication. In order to be more competitive, however, a company may choose not to raise the rates in a territory by the full indication. In this way, each territorys rates are developed based on the relative difference in their losses and premiums compared to all the other territories across the state. The Departments verifies all of the data calculations in the 5 steps above.

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