Certification of Compliance for all Property/Casualty Rate, Rule or Rate/Rule Filings

COMMISSIONER OF SECURITIES AND INSURANCE Troy Downing Office of the Commissioner Montana State Auditor 840 Helena Avenue, Helena, Montana 59601 (main fax) 406.444.3413 I (securities fax) 406.444.5558 (insurance consumer services fax) 406.444.1980 I (legal fax) 406.444.3499 (phone) 800.332.6148 or 406.444.2040 I (email) csi@mt.gov I (web) www.csimt.gov ADVISORY MEMORANDUM To: ALL INTERESTED PERSONS From: TROY DOWNING Commissioner of Securities and Insurance, Office of the Montana State Auditor Date: 07/25/2023 Advisory Memorandum Regarding Certification of Compliance for all Property/Casualty Rate, Rule or Rate/Rule Filings. Background The Commissioner of Securities and Insurance (CSI) recently completed a review of its internal rate review processes and procedures to identify efficiencies in the use of current agency resources. This review revealed that a significant number of compliance issues in property/casualty rate, rule or rate/rule filings could be avoided by requiring a certification that the filing complies with Title 33 of the Montana Code and Chapter 6.6 of the Montana Administrative Rules. Guidance Effective September 1, 2023, CSI will require that all property and casualty rate, rule or rate/rule filings be accompanied by a certification that, to the best of an officer’s knowledge and belief, the rate, rule or rate/rule filing complies with Title 33 of the Montana Code and Chapter 6.6 of the Montana Administrative Rules. The certification will further require the officer to certify that the officer has reviewed the CSI’s P & C Rate/Rule Filing Guide. The P & C Rate/Rule Filing Guide and the Certification form are both available on the CSI’s website at https://csimt.gov/insurance/rates/. July 25, 2023 Page 2 Submittal of this Certification does not excuse compliance with any provision of Montana law. This advisory memorandum is informational only and does not enlarge, delimit, or otherwise modify any requirements of applicable law or in any way limit the authority of CSI under applicable law. CSI encourages interested persons to consult with independent legal counsel for guidance on the application of law to any particular circumstances. Effective Date 9/1/23