Price Optimization White Paper Draft Comments To Be Reviewed at NAIC Casualty Actuarial and Statistical Task Force July 21 Meeting

Jul 13, 2015

Florida Insurance Lobbyist Donovan Brown

Above:  Colodny Fass’ Donovan Brown Notes Comments Submitted on NAIC Price Optimization Draft White Paper


“At what point can a proposed rate be judged as “unfairly discriminatory?”

“Is it really the responsibility of a regulated entity to explain to its regulator why a particular practice is not unlawful?”

“The (insurance) industry (has a) penchant for avoiding regulatory scrutiny of risk classifications by calling them something else . . . . Regulators need to stop this verbal arbitrage by insurers.”

These and other colorful, pointed comments were those recently published by the National Association of Insurance Commissioners (“NAIC”) Casualty Actuarial and Statistical Task Force (“Task Force”) on a draft white paper covering the growing issue of “price optimization” in insurance ratemaking.

To view the draft white paper, click here.  To access the complete comment package, click here.

Those providing feedback included the American Academy of Actuaries, the American Insurance Association, the Casualty Actuarial Society, the Consumer Federation of America and the Center for Economic Justice, the National Association of Mutual Insurance Companies, and Arthur Schwartz, a North Carolina Department of Insurance actuary who sent his comments as an individual.

The Task Force will discuss the price optimization comments on a July 21, 2015 conference call. 



Should you have any questions or comments, please contact G. Donovan Brown at Colodny Fass (+1 850 545 8864 or



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