Florida Hurricane Catastrophe Fund Advisory Council To Review Proposed Insurer Reporting Requirements and Responsibilities Rules for 2015-2016 Contract Year
Feb 5, 2015
The Florida Hurricane Catastrophe Fund (“FHCF”) Advisory Council is scheduled to meet today, February 5, 2015, at 1:30 p.m. (ET) to address insurer reporting requirements and responsibilities for the 2015-2016 FHCF Contract Year.
Election of an FHCF Vice Chair and a discussion of the 2015 FHCF Data Call are also on the agenda.
To access information on each of the proposed Rules, click on the hyperlinks below:
The meeting will take place in Tallahassee, however it is accessible via conference call using the following number: 1(888) 670-3525 and enter conference code: 7135858151
Below are summaries of proposed changes for each Rule as of yesterday:
19-8.029, Insurer Reporting Requirements and Incorporated Forms/2015-2016 FHCF Contract Year
(2)(a) The definition of Citizens Property Insurance Corporation is revised to specify that the term refers to two accounts (the Coastal Account and the PLA/CLA account), and that each of these accounts is to be treated as if it were a separate participating insurer. These changes make the definition consistent with the definition used in the Reimbursement Contract under Rule 19-8.010.
(2)(c) Editorial change: The time references in the definition of contract year are clarified.
New paragraph (2)(k) is added to provide a definition of “WIRE.” WIRE is the Web Insurer Reporting Engine used for the reporting of insurer exposure data.
(3)(a) Editorial change: The current requirement for online data reporting is clarified by the addition of a requirement that WIRE be used for such reporting. This change reflects current practice.
(3)(d), relating to deadlines for online data reporting, is amended to require an electronic sign-off by two officers for each WIRE submission. This change reflects current practice.
Existing (4)(a) relating to the Data Call for the 2010-2011 Contract Year is deleted as obsolete material and existing (4)(b) through (4)(e) are redesignated as (4)(a) through (4)(d), respectively.
New (4)(e) is added to adopt the Data Call for the 2015-2016 Contract Year, Form FHCF-D1A rev. XX/15.
(5)(a) and (b) are amended to delete a cross-reference to subsection (8), relating to how to obtain a copy of the forms for the Interim Loss Report and the Proof of Loss Report.
(5)(b) is amended to delete an obsolete reference to the hard-copy Proof of Loss Report.
Existing (6)(a) and (b), relating to various loss reporting forms for the 2005-2006 and 2013-2014 Contract Years are deleted as obsolete material, existing (6)(c) is renumbered as (6)(a), and a new (6)(b) is added to adopt the Interim Loss Report, Proof of Loss Report, and Detailed Claims Listing Instructions for the 2015-2016 Contract Year.
Incorporated Forms
FHCF-D1A rev. XX/15, Florida Hurricane Catastrophe Fund 2015 Data Call
In addition to updating references to apply to the 2015 Contract Year, the 2015 Data Call includes the following changes:
Important Changes in the 2015 Data Call. This section summarizes the two substantive changes in the 2015 Data Call: the addition of a Construction Mapping Worksheet to facilitate a participating insurer’s ability to submit its proposed construction code mapping for review prior to submitting the Data Call; and the addition of fields for the reporting of the street addresses of properties insured under covered policies.
FHCF WIRE (Web Insurer Reporting Engine). This new paragraph summarizes the requirement that all Data Call submissions be made using WIRE, including requirements relating to WIRE accounts and account managers, registered users, and officers. This paragraph incorporates the provisions of former paragraph 2 of “Steps for Completing the Data Call,” which is deleted.
Steps for Completing the Data Call.
- A new paragraph 1 is added to include the suggestion that a company’s WIRE users verify their access well in advance of submitting the Data Call, and to include a telephone number for assistance.
- Existing paragraph 2, the substance of which was moved to “FHCF WIRE (Web Insurer Reporting Engine)” is deleted.
- Paragraph 3 is amended to clarify requirements relating to the validation tests that must be passed before submitting the Data Call.
- A footnote to paragraph 6 is amended to delete the request that a company use one individual to coordinate, compile, and submit its data. This is now obsolete with the implementation of WIRE.
General Data Call Issues.
- This section was amended to include an email address to reach Paragon for assistance with the Data Call.
File Layout and Description of Data Fields.
- This section is revised to add two new fields: Field 13 for the street name and number of an insured property and Field 14 for secondary address information, if any.
- The description of Field 3, Construction Type, is revised to incorporate the new Construction Mapping Worksheet. The worksheet must be submitted to and approved by the FHCF Administrator before a company can use construction codes and definitions that differ from the FHCF’s construction codes and definitions. Where no construction information is captured, construction code 11 is to be used in all cases except for mobile homes, which use construction code 25. References to “default” construction codes 12 and 26 are deleted.
- The description of Field 4, Deductible Group, includes several non-substantive edits.
- The description of Field 20, Citizens Policy Number, is amended to include reporting instructions for companies that did not assume any policies from Citizens.
Reimbursement Contract Definitions and Exclusions. The sections of the Data Call that reprint selected definitions and exclusions as used in the Reimbursement Contract is updated to reflect the language of the 2015-2016 Reimbursement Contract.
Reporting Clarifications. An existing sentence in item 3 of Commercial-Habitational Clarifications relating to exposures in different ZIP Codes is relocated for clarity.
Citizens Property Insurance Corporation Takeouts Pursuant to Assumption Agreements. In addition to several non-substantive editorial changes, language is added to clarify that the Citizens Property Insurance Corporation exposure reports include assumed policies for which the policyholder opted out of the assumption on or before June 30, 2015 and which were not assumed by another company prior to that date.
FHCF Construction Codes. Default construction codes are deleted.
Construction Mapping Worksheet. The Worksheet is provided to facilitate a participating insurer’s ability to submit its proposed construction code mapping for review and approval before submitting the Data Call. The Worksheet requires the insurer to specify whether it captures the number of stories of multi-story buildings, provide construction types and definitions from its underwriting manual, and the FHCF code proposed for each classification.
Supplemental Instruction Sheet for New Participants. Language is added applying the section on Citizens Property Insurance Corporation Takeouts Pursuant to Assumption Agreements to new participants that were participating in an assumption agreement with Citizens from June 1, 2015 through November 30, 2015, but with an “as-of” date of November 30, 2015 rather than June 30, 2015.
FORM FHCF-LIA rev. XX/15, Contract Year 2015 Interim Loss Report
References are updated to apply to the 2015 Contract Year.
FORM FHCF-L1B rev. XX/15, Contract Year 2015 Proof of Loss Report
References are updated to apply to the 2015 Contract Year.
FORM FHCF-DCL rev. XX/15, Contract Year 2015 Detailed Claims Listing Instructions
References are updated to apply to the 2015 Contract Year.
19-8.030, Insurer Responsibilities, F.A.C. and Incorporated Forms/2015-2016 FHCF Contract Year
(3)(d) The definition of Citizens Property Insurance Corporation is revised to specify that the term refers to two accounts (the Coastal Account and the PLA/CLA account), and that each of these accounts is to be treated as if it were a separate participating insurer. These changes make the definition consistent with the definition used in the Reimbursement Contract under Rule 19-8.010.
(3)(e) Editorial change: The time references in the definition of contract year are clarified.
(3)(q) Editorial change: Corrects a statutory cross-reference.
New paragraph (3)(r) is added to provide a definition of “WIRE.” WIRE is the Web Insurer Reporting Engine used for the reporting of insurer exposure data.
(4)(a) Editorial change: Clarifies references to 2010-2011 and 2011-2012 Contract Years.
(4)(c) Editorial change: Clarifies a reference to certain New Participants.
(5)(a) Editorial change: Corrects a statutory cross-reference.
(5)(b) This paragraph is amended to clarify that the Data Call must be submitted online using WIRE.
(5)(c) Editorial change: Clarifies references to 2012-2013 and 2013-2014 Contract Years.
(5)(d) This paragraph is amended to require that resubmissions for the 2013-2014 Contract Year and earlier Contract Years be submitted manually to the FHCF Administrator in accordance with the Data Call for the applicable Contract Year, and that resubmissions for the 2014-2015 Contract Year and subsequent Contract Years be submitted online using WIRE.
(6) Editorial change: The term “FHCF” is inserted and “Fund” deleted.
(7)(a) Editorial change: Corrects a statutory cross-reference.
Existing (7)(d), relating to reimbursement premium due from a company that is in receivership, rehabilitation, or regulatory supervision is deleted as duplicative of other material. The applicable requirements are specified in Article X, paragraph (2)(b) of the Reimbursement Contract adopted under Rule 19-8.010.
Existing (8)(a) Subparagraphs 1, 2, and 3, relating to exposure examination instructions and loss reimbursement examination instructions for Contract Years 2005-2006, 2009-2010, and 2010-2011, are deleted as obsolete material and subsequent subparagraphs are renumbered. New subparagraph 5, adopting the exposure examination instructions and loss reimbursement examination instructions for Contract Year 2015-2016 is added.
(8)(c) and (d), relating to responses to FHCF examination reports, are amended to authorize, rather than require, a company to outline its reasons for disagreement, and to authorize, rather than require, the FHCF to grant the company a 30-day extension upon an appropriate showing.
(9)(a) Editorial change: Clarifies a reference to resubmission of data.
Incorporated Forms
FORM FHCF-EAP1 rev. XX/15, Exposure Examination-Contract Year 2015 Advance Preparation Instructions
References are changed throughout to apply to the 2015-2016 Contract Year and to reflect the ongoing implementation of the FHCF WIRE online exposure reporting system.
Advance Records. The records that a company is to submit in advance of the examiner’s on-site review must be submitted through WIRE, rather than by CD-ROM. In addition to editorial changes, the records checklist requirement is revised to delete the reference to hard copy Examination Reports. In addition, paragraph 2 is revised to require the Operations Questionnaire be submitted as an Excel file. Paragraph 3 is revised to reference the Construction Mapping Worksheet in the 2015 Data Call and specify what must be submitted as part of the advance records. Paragraph 4 is amended to require that the Forms and Endorsements listing be provided in an Excel file. Existing paragraph 6 is deleted as obsolete material. Renumbered paragraph 6 is revised to require the Direct Written Premium Report in a pipe delimited file. New paragraph 7 is added to require the advance records to include a copy of the company’s underwriting manual and rating manual (currently, this is required to be provided on-site rather than in advance).
On-site Requirements. Editorial changes for clarity.
Additional On-site Requirements. The requirement that a copy of the company’s underwriting manual and rating manual be provided on-site is deleted (this material must now be provided as part of the advance records).
Post-exam Requirements. This paragraph is added to provide that the examiner or the FHCF may request additional information or documentation after completion of the on-site review.
Special Exams Related to Citizens Property Insurance Corporation. Editorial changes for clarity.
FORM FHCF-LAP1 rev. XX/15, Loss Reimbursement Examination-Contract Year 2015 Advance Preparation Instructions
References are changed throughout to apply to the 2015-2016 Contract Year.
Advance Records. Adds a requirement that the company submit the Records Checklist and Operations Questionnaire in the file format and file type in which it was sent to the company.
Required Records Checklist. In addition to non-substantive editorial changes, this paragraph provides for designation of a company’s claims contact and actuarial contact.
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