Extension of Comment Period for General Requirements and Filing Instructions for Property and Casualty Rate, Rule and Form Filings

JOSH GREEN, M.D. GOVERNOR | KE KIAʻĀINA SYLVIA LUKE LIEUTENANT GOVERNOR | KA HOPE KIAʻĀINA STATE OF HAWAII | KA MOKUʻĀINA ʻO HAWAIʻI DEPARTMENT OF COMMERCE AND CONSUMER AFFAIRS KA ʻOIHANA PILI KĀLEPA INSURANCE DIVISION 335 MERCHANT STREET, ROOM 213, HONOLULU, HAWAII 96813 P.O. BOX 3614, HONOLULU, HAWAII 96811 Phone Number: (808) 586-2790 Fax Number: (808) 587-6714 cca.hawaii.gov/ins/ NADINE Y. ANDO DIRECTOR | KA LUNA HOʻOKELE SCOTT K. SAIKI INSURANCE COMMISSIONER January 9, 2026 MEMORANDUM 2026-1PC To: All Authorized Insurers Offering Property and/or Casualty Policies in the State of Hawaii From: Scott K. Saiki, Insurance Commissioner Subject: Extension of Comment Period for General Requirements and Filing Instructions for Property and Casualty Rate, Rule and Form Filings Due to positive feedback, the Division’s revised Property & Casualty (“P&C”) rate filing procedures, discussed in Commissioner’s Memorandum 2025-10R (issued on November 10, 2025) and 2025-11R (issued on November 24, 2025) have been further refined as follows: • RF1 Cover Page: o Added instructions to submit applicable forms, rather than the entire workbook. • RF10 General Requirements: o Amended Footnote 5 to include limitation to Personal Lines, COMFAL, and Dwelling products. • RF11 P&C Filing Instructions: o Added notation to 5a.C. that clarifying endorsements are exempt from rate impact analysis; Memorandum 2026-1PC January 9, 2026 Page 3 o Added distinction to 5b.D. requirements regarding loss cost impact analysis expectations pertaining to independent coverage restrictions; o Added limitation of RF14 Forms Worksheet, to applicable sections, for independent forms ONLY; o Added limitation to 6a.D. to Personal Lines products, COMFAL and Dwelling Fire; o Reverted 6a.F.v.a. to the existing requirement of justifying all changes which impact the rate level; o Amended 6a.F.vi. to provide clarity regarding disclosure and possible effects of loss data removal; o Corrected 6a.F.v.b. reference from “6a.G.v.a.” to “6a.F.v.a.”; o Added Prohibited Rating Variables and statutory reference for Motor Vehicle in 6a.H.a.; o Added clarification to 6a.H.c. that risk classification by county is permissible; o Added language to 6d.E.iv. regarding expected supporting documentation; and o Added notation to 6.d.E.v. reinforcing that period loss ratio can be undeveloped. • RF12 Rate Summary: o Removed DCCE/AOE LOADS table – table 4. • RF14 Forms Worksheet o Added notice that input is limited to independent forms and removed “Independent or Advisory Column”. The revised materials are titled “Hawaii General Requirements and Filing Instructions v1.1” and are now available on SERFF and at the Insurance Division’s website at https://cca.hawaii.gov/ins/insurers/rate_policy/. Memorandum 2026-1PC January 9, 2026 Page 3 The effective date for the revised General Requirements and Filing is extended to April 1, 2026. Insurers must ensure that all filings submitted on or after April 1, 2026, conform to the revised requirements and forms. Filings submitted prior to April 1, 2026 (including those filings currently pending an approval) are not required to be conformed and re-filed. For questions, please contact Grant Shintaku by email at insrpapc@dcca.hawaii.gov, or by phone at (808) 586-2809. The Commissioner acknowledges the Insurance Division P&C staff for their work to modernize the rate filing process.