Property and Casualty Insurance (C) Committee

2015 Summer National Meeting Chicago, Illinois Property and Casualty Insurance (C) Committee August 17, 2015 2015 National Association of Insurance Commissioners

Consider Adoption of its May 15 and 4, 2015 Minutes Attachment One 2015 National Association of Insurance Commissioners

Attachment Property and Casualty Insurance (C) Committee 8/17/15 Draft: 7/30/15 Property and Casualty Insurance (C) Committee Conference Call May 15, 2015 The Property and Casualty Insurance (C) Committee met via conference call May 15, 2015. The following Committee members participated: Mike Chaney, Chair (MS); Jim L. Ridling represented by Charles Angell (AL); Tom Donovan (ID); James Stephens and John Gatlin (IL); James J. Donelon represented by Warren Byrd (LA); John G. Franchini represented by Alan Seeley (NM); Raymond G. Farmer (SC); Larry Deiter (SD); and Michael D. Riley (WV). Also participating was: Paula Pallozzi (RI). 1. Adopted Revised Cybersecurity Insurance Coverage Supplement to the Annual Statement Commissioner Chaney said additional comments on the Cybersecurity Insurance Coverage Supplement were received after the Committee s May 4, conference call. Sara Robben (NAIC) explained that a new draft was created that requests identity theft insurance information; removes the ranges of limits for cybersecurity insurance; revises the definition of cybersecurity insurance based on suggestions from American Insurance Association (AIA); and revises the instructions. Lisa Brown (AIA) said she was not sure what was meant by a package policy. Ms. Robben said it refers to any policy with cyber coverage added to it. Ms. Brown also said the definitions still need clarification on how to report identity theft coverage. Ms. Pallozzi suggested separately defining identity theft as a personal line coverage within the instructions. Upon a motion by Director Farmer, seconded by Mr. Angell, the Committee agreed to make the revisions discussed by Ms. Robben and Ms. Pallozzi. Stephen Broadie (Property Casualty Insurers Association of America PCI) expressed concern that the definition of cybersecurity insurance was overly broad and might require companies to include incidental cyber coverage as part of a package policy. Ms. Pallozzi said the definition may be broad because regulators want to collect any cyber risks covered by insurance companies. Director Farmer agreed and said regulators are looking for as much data as they can get. Ms. Brown said the AIA believes some of the data is confidential and they will bring this issue before the Blanks (E) Working Group as that group considers the proposal. Mr. Broadie agreed with potential confidentiality issues and said the cost of providing the data for some companies may exceed the benefits gained. Commissioner Chaney said he is comfortable with what data is being requested, noting that the goal is to get as much data as possible. He said the Blanks (E) Working Group can look into issues related to confidentiality. Eric Nordman (NAIC) said one of the purposes of collecting this data is to inform consumers and the federal government on the size of the cyber insurance market. Mr. Broadie said there is a difference between reporting on the size of the market and making individual company data available. Mr. Nordman said the data is not policyholder-level data, but is similar to market share data that the NAIC releases for other types of coverage. Ms. Pallozzi said she believes the most recent draft is a good compromise, as it removes the range of limits that may be difficult to collect. Commissioner Chaney said the intent of the blanks proposal is to be broad enough to provide good data to regulators and the public. He said the next step would be an exposure period by the Blanks (E) Working Group and a conference call of the Blanks (E) Working Group to be held June 30. Upon a motion by Director Farmer, seconded by Mr. Byrd, the Committee adopted the revised Cybersecurity Insurance Coverage Supplement for submission to the Blanks (E) Working Group. Having no further business, the Property and Casualty Insurance (C) Committee adjourned. W:\National Meetings\2015\Summer\Cmte\C\05-15 Cmin.docx 2015 National Association of Insurance Commissioners 1

Draft: 7/30/15 Attachment Property and Casualty Insurance (C) Committee 8/17/15 Property and Casualty Insurance (C) Committee Conference Call May 4, 2015 The Property and Casualty Insurance (C) Committee met via conference call May 4, 2015. The following Committee members participated: Mike Chaney, Chair (MS); John D. Doak, Vice Chair (OK); Lori K. Wing-Heier (AK); Jim L. Ridling represented by Charles Angell (AL); Katharine L. Wade represented by George Bradner (CT); Kevin M. McCarty represented by David Altmaier (FL); Tom Donovan (ID); James Stephens (IL); James J. Donelon represented by Warren Byrd and Tom Travis (LA); Raymond G. Farmer (SC); and Michael D. Riley (WV). Also participating was: Paula Pallozzi (RI). 1. Adopted its Spring National Meeting Minutes Commissioner Riley made a motion, seconded by Mr. Altmaier, to adopt its March 30 minutes (see NAIC Proceedings Spring 2015, Property and Casualty Insurance (C) Committee March 30, minutes). The motion passed. 2. Adopted the Cybersecurity Insurance Coverage Supplement to the Annual Statement Commissioner Chaney said the proposed draft Cybersecurity Insurance Coverage Supplement and related instructions were revised following discussion of comments at the Spring National Meeting. Commissioner Chaney said the American Insurance Association (AIA) submitted some additional comments (Attachment A). He said there is some discussion amongst regulators about potentially adding disclosure regarding identify theft, but he suggested postponing such discussion. Sara Robben (NAIC) described changes made to the supplement as a result of submitted comments. Angela Gleeson (AIA) said the definition of cybersecurity is broad, and must be to cover the stand-alone policies. But the broad definition causes problems when evaluating a multi-package policy. The AIA believes the Committee should decide the purpose of reporting for solvency assessment or to understand the market. She said the limit ranges are not going to provide helpful information to understanding the most common limits. Mr. Nordman suggested the AIA propose something other than the range. Dave Snyder (Property Casualty Insurers Association of America PCI) said the definition seems to have expanded the scope and types of policies covered. Ms. Robben said the definition was rewritten based upon comments submitted by the AIA. Ms. Pallozzi said the expanded definition comes from the federal government. Paul Tetrault (National Association of Mutual Insurance Companies NAMIC) said some of the information is proprietary and could signal competitive position in the market place, especially for niche writers. Commissioner Chaney said NAMIC might want to address that issue at the Blanks (E) Working Group. Birny Birnbaum (Center for Economic Justice CEJ) said there is no evidence for the assertion that this data should be held confidential. He said the same type of information is available for other types of insurers. He said an option for the range of liabilities would be to request the number of policies by limit grouping. It is more efficient and effective to collect transaction-level data. He said this data could be held confidential. Mr. Travis made a motion, seconded by Director Wing-Heier, to adopt the amended draft supplement for submission to the Blanks (E) Working Group (Attachment B). The motion passed. 3. Appointed the Creditor-Placed Insurance Model Act Review (C) Working Group Commissioner Chaney said the Committee is charged with updating the Creditor-Placed Insurance Model Act (#375). Initially, the Committee was going to review the data call information prior to commencing work. In light of the delay in receipt of that data, Commissioner Chaney asked that work commence with formation of a working group chaired by Mr. Altmaier. It was moved and seconded that the Committee establish a Creditor-Placed Insurance Model Act Review (C) Working Group. The motion passed. 2015 National Association of Insurance Commissioners 1

Attachment Property and Casualty Insurance (C) Committee 8/17/15 4. Discussed the Casualty Actuarial and Statistical (C) Task Force Charges Commissioner Chaney expressed support of the Casualty Actuarial and Statistical (C) Task Force to complete its charge regarding the Society of Actuary s (SOA) new general insurance educational track. Having no further business, the Property and Casualty Insurance (C) Committee adjourned. W:\National Meetings\2015\Spring\Cmte\C\05-4 Cmin.docx 2015 National Association of Insurance Commissioners 2

Consider Adoption of its Task Force and Working Group Reports Attachment Two 2015 National Association of Insurance Commissioners

2015 Summer National Meeting Chicago, Illinois CASUALTY ACTUARIAL AND STATISTICAL (C) TASK FORCE Saturday, August 15, 2015 9:00 10:30 a.m. Meeting Summary Report The Casualty Actuarial and Statistical (C) Task Force met Aug. 15, 2015. During this meeting, the Task Force: 1. Adopted its April 14, May 19, June 2, June 16, June 23, June 30 and July 21minutes, which included: Adoption of a response to the Property and Casualty Insurance (C) Committee regarding the Society of Actuary s General Insurance Actuarial Education Track. 2. Adopted the reports of its Actuarial Opinion (C) Working Group, Appointed Actuary (C) Subgroup, and Statistical Data (C) Working Group. 3. Exposed the draft Price Optimization White Paper and recommendations for a 30-day comment period ending Sept. 8. This paper will aid members decisions about actions to take regarding any use of price optimization by insurers. 4. Heard reports from the American Academy of Actuaries (Academy) regarding the Academy s work to aid appointed actuaries opining on P&C reserves and to enforce actuarial professionalism and adherence to actuarial standards. W:\National Meetings\2015\Summer\Summaries\Final Summaries\CASTF.docx 2015 National Association of Insurance Commissioners 1

Surplus Lines (C) Task Force did not meet at the National Meeting 2015 National Association of Insurance Commissioners

2015 Summer National Meeting Chicago, Illinois TITLE INSURANCE (C) TASK FORCE Sunday, August 16, 2015 4:00 5:00 p.m. Meeting Summary Report The Title Insurance (C) Task Force met Aug. 16, 2015. During this meeting, the Task Force: 1. Adopted its July 30 and May 6 minutes, which included adoption of the Title Insurance Consumer Shopping Tool template and its companion best practices guide, Options for Regulators to Distribute a Title Insurance Consumer Shopping Tool. The Task Force also disbanded the Title Insurance Guaranty Fund (C/E) Working Group and had multiple discussions regarding affiliated business arrangements and updates to the survey of state insurance laws regarding title data and title matters. 2. Adopted the reports of the Title Insurance Financial Reporting (C) Working Group and the Title Insurance Consumer Shopping Tools (C) Working Group. The Title Financial Reporting (C) Working Group submitted a proposal to the Statutory Accounting Principles (E) Working Group to revise language in the quarterly disclosure in SSAP No. 55 Unpaid Claims, Losses and Loss Adjustment Expenses and the title annual statement instructions, Notes to Financial Statements No. 25. This disclosure is currently uniform for all statement types; however, title reporting entities utilize slightly different terminology. The Title Insurance Consumer Shopping Tools (C) Working Group has completed its work on the Title Insurance Consumer Shopping Tool template and its companion best practices guide, Options for Regulators to Distribute a Title Insurance Consumer Shopping Tool and began drafting a shorter title insurance consumer brochure. 3. Heard an update on federal activities. U.S Rep. Keith Ellison proposed H.R. 1799, Ensure Fair Prices in Title Insurance Act, to amend the federal Real Estate Settlement Procedures Act of 1974. The purpose of the bill it to prohibit any referral source such as a realtor, builder or mortgage broker from receiving a financial benefit for referring homebuying clients to a title insurance firm. The bill prescribes that restitution be provided to clients and competitors from firms breaking the law and extends the statute of limitation from one to three years. 4. Discussed affiliated business arrangements (AfBA) including federal requirements, current activities and individual state laws regarding AfBA and made suggestions for how the Task Force can address the issue collectively. 5. Discussed the survey of state insurance laws regarding title data and title matters. A majority of the states have completed the survey. The Task Force agreed to give the remaining jurisdictions two weeks to respond before compiling the results and conducting a conference call to discuss the results. 6. Heard a presentation from the American Land Title Association (ALTA) on its Homebuyer Outreach Program. The Homebuyer Outreach Program was created to protect homebuyers by educating them about the value of purchasing owner s title insurance. W:\National Meetings\2015\Summer\Summaries\Final Summaries\TitleTF.docx 2015 National Association of Insurance Commissioners

Workers Compensation (C) Task Force summary available as a separate handout 2015 National Association of Insurance Commissioners

2015 Summer National Meeting Chicago, Illinois ADVISORY ORGANIZATION EXAMINATION OVERSIGHT (C) WORKING GROUP (Regulator-to-Regulator Session) Saturday, August 15, 2015 10:00 11:30 a.m. Meeting Summary Report The Advisory Organization Examination Oversight (C) Working Group met Aug. 15, 2015. During this meeting, the Working Group: 1. Heard comments from the following Advisory Organization representatives regarding the Comprehensive Annual Audit Form proposed at the Spring National Meeting: Mona Carter (National Council on Compensation Insurance NCCI), Mary Van Sise (Insurance Services Office ISO), Susan Miller and Randi Cigelnik (Independent Statistical Service ISS), Lenore Marema (Surety & Fidelity Association of America SFAA), Robin Westcott (American Association of Insurance Services AAIS). 2. Received a status update on the National Crop Insurance Services (NCIS) Exam. 3. Received a status update on the Auto Insurance Plans Service Office (AIPSO) Exam. 4. Received a status update on the National Independent Statistical Service (NISS) Exam. 5. Discussed plans for the 2016 National Council on Compensation Insurance (NCCI) Exam. W:\National Meetings\2015\Summer\Summaries\AOEOWG 2015 National Association of Insurance Commissioners 1

Affordable Care Act Medical Professional Liability (C) Working Group did not meet at the National Meeting 2015 National Association of Insurance Commissioners

2015 Summer National Meeting Chicago, Illinois AUTO INSURANCE (C/D) STUDY GROUP Saturday, August 15, 2015 3:00 4:00 p.m. Meeting Summary Report The Auto Insurance (C/D) Study Group met Aug. 15, 2015. During this meeting, the Study Group: 1. Adopted its Spring National Meeting minutes, which included: 1) discussion of the data template related to risk classifications and 2) a presentation regarding the TransUnion/CARFAX rating tool. 2. Discussed the data template related to risk classification and a new introduction meant to provide the background and purpose of the template. Commissioner Daniel R. Judson (MA) asked that comments on the template and overview document be submitted by the end of August. 3. Discussed a Federal Insurance Office (FIO) request for comment on FIO s proposed methodology and data related to an affordability of auto insurance study. The Working Group heard from Birny Birnbaum (Center for Economic Justice), Dave Snyder (Property Casualty Insurers Association of America) and Robert Detlefsen (National Association of Mutual Insurance Companies) on their thoughts related to the FIO proposed study. 4. Discussed an article from Consumer Reports and a report from the Consumer Federation of America about the use of certain variables in auto insurance rating. W:\National Meetings\2015\Summer\Summaries\Final Summaries\AutoSG.docx 2015 National Association of Insurance Commissioners 1

2015 Summer National Meeting Chicago, Illinois CATASTROPHE INSURANCE (C) WORKING GROUP Sunday, August 16, 2015 11:00 a.m. 12:00 p.m. Meeting Summary Report The Catastrophe Insurance (C) Working Group met Aug. 16, 2015. During this meeting, the Working Group: 1. Adopted its March 29 minutes, which included: 1) adoption of its Spring National Meeting minutes; 2) a report from the Consumer Outreach and Assistance Post-Disaster (C) Subgroup; 3) a report from the Post-Catastrophe Regulatory Guidance (C) Subgroup; 4) an update on the National Flood Insurance Program (NFIP) and catastrophe-related legislation; 5) a presentation from Karen Clark regarding her company s RiskInsight U.S. storm surge model; and 6) a presentation regarding the status of the Federal Emergency Management Agency s (FEMA) Superstorm Sandy lawsuits. 2. Adopted the Post-Catastrophe Regulatory Guidance (C) Subgroup s Aug. 11 minutes and the Subgroup s report. The Subgroup received 37 responses to a survey sent out to the states regarding states statutes and regulations regarding catastrophes, as well as questions relating to underwriting and the various state departments procedures. NAIC staff are to follow-up with the states that did not respond to the surveys. NAIC staff will also supply specific summary information for all yes responses. The Subgroup will hold a call toward the end of September to discuss the results. The Subgroup will discuss how the updates will be submitted for initial summary review, as well as yearly updates. It will also discuss how to fulfill its charge i.e., model law/regulation or guideline versus a tool that regulators can use as a reference to consider adopting similar requirements via legislative or regulatory initiatives. 3. Adopted the Consumer Outreach and Assistance Post-Disaster (C) Subgroup s July 27 minutes and the Subgroup s report. The Subgroup discussed sending a survey out to industry by way of the trade associations to gather information regarding insurer practices following a catastrophic event. The responses the Subgroup receives from industry would be used to guide the Subgroup s deliverables, rather than identifying how each company handles claims. The draft questions are included in the Subgroup s minutes, as well as the discussion the Subgroup held regarding the survey questions. The Subgroup will meet via conference call in September to discuss the survey questions and possible revisions. NAIC staff also provided the Subgroup with a draft claims guide. NAIC staff will continue to add to the claims guide. This guide is intended to guide consumers through the processes following a catastrophic event. Additionally, NAIC staff will provide the Subgroup with a list of faith-based organizations, their contact information and information regarding the services each organization provides. 4. Received an update on the NFIP and catastrophe-related legislation. The NFIP Regulator Handbook being written by FEMA staff is expected to be available by the end of the year. Congress required an affordability study, which includes studying the feasibility of means tested vouchers. In addition, FEMA and the Government Accountability Office (GAO) are required to conduct privatization studies. In April, FEMA began implementing a number of changes stemming from the flood reform laws. These changes include: 1) an additional deductible option; 2) a new annual surcharge; and 3) implementing annual rate changes that set rates using rate-increase limitations set forth by the 2014 reform law. The U.S. House of Representatives and U.S. Senate Financial Services Government spending bills include language prohibiting the use of funding to implement the Obama administration s Federal Flood Risk Management Standard, which would require higher base flood level elevations for federally funded investments, until Congress is satisfied public input has been adequately considered. The federal banking regulators have still not released their final rulemaking regarding private flood insurance. The NAIC has endorsed the Flood Insurance Market Party and Modernization Act to help spur the development of the private flood market. Congress continues to focus on its oversight on examining FEMA s handling of the Superstorm Sandy claims process. In June, the Senate Banking Committee issued a report assessing the NFIP s management and accountability following Superstorm Sandy. 2015 National Association of Insurance Commissioners

Finally, the NAIC has endorsed the Disaster Savings Accounts Act to address natural catastrophe preparation and recovery. 5. Heard a presentation from Guy Carpenter regarding LiveCat/Deductible Buy-Down. This product enables personal and commercial consumers to purchase coverage to protect against potential losses due to a live windstorm in the Atlantic/Gulf hurricane basin in the retention/deductible of a current policy. The coverage can be purchased both on a LiveCat basis that is, when a live windstorm is present and on a pre-season basis. The products allow insureds to both buy-down their current deductible and obtain coverage for gaps and/or exclusions within their traditional coverage. There is some question as to whether this is an actual insurance product. W:\National Meetings\2015\Summer\Summaries\FInal Summaries\CatIns.docx 2015 National Association of Insurance Commissioners 2

Catastrophe Response (C) Working Group summary available as a separate handout 2015 National Association of Insurance Commissioners

2015 Summer National Meeting Chicago, Illinois CLIMATE CHANGE AND GLOBAL WARMING (C) WORKING GROUP Saturday, August 15, 2015 8:00 9:00 a.m. Meeting Summary Report The Climate Change and Global Warming (C) Working Group met Aug. 15, 2015. During this meeting, the Working Group: 1. Adopted its March 28 minutes, which included: 1) a presentation from Munich Re America on its multi-faceted climate change strategy; and 2) a presentation from Ceres on briefing materials developed to educate financial examiners on how climate risks and opportunities affect insurer solvency. 2. Heard a presentation from Deb Clarke, Global Head of Investment Research at Mercer, on Mercer s Investing in a Time of Climate Change report. The report represents a unique and unprecedented effort to model the complex affects of climate change on the diversified portfolios of institutional investors, including insurers. W:\National Meetings\2015\Summer\Summaries\Final Summaries\Climate.docx 2015 National Association of Insurance Commissioners 1

Attachment -- Property and Casualty Insurance (C) Committee 8/17/15 Draft: 8/12/15 Creditor-Placed Insurance Model Act Review (C) Working Group Conference Call Aug. 6, 2015 The Creditor-Placed Insurance Model Act Review (C) Working Group of the Property and Casualty Insurance (C) Committee met via conference call Aug. 6, 2015. The following Working Group members participated: David Altmaier, Chair, and Robert Lee (FL); Joel Laucher (CA); Carrie Couch (MO); David Browning (MS); Buddy Combs (OK); Elizabeth Dwyer (RI); Mark Worman and Jennifer Soldano (TX); Rebecca Nichols (VA); and Jason Levine (WI). 1. Reviewed the Working Group Charge Mr. Altmaier said the charge for the Working Group reads: Review information from the public hearing on lender-placed insurance and determine if changes to the Creditor-Placed Insurance Model Act (#375) are warranted. Make recommendations for changes, if warranted. Complete work on the model by the 2015 Fall National Meeting. He said the Working Group would review the 2012 public hearing, as well as what actions states have taken to address individual lender-placed insurers or the market as a whole. 2. Reviewed the Key Takeaways from the 2012 Public Hearing Mr. Altmaier said NAIC staff had drafted a document that summarized key takeaways from the 2012 public hearing on lender-placed insurance. He said it is not planned that the document would be adopted but that it would guide discussion within the Working Group. He said the document includes opinions from industry proponents and from consumer groups. Mr. Lee said three carriers write virtually all of the lender-placed insurance business. He said he disagrees with the industry argument that the market does not experience reverse competition. He said the financial institution is the named insured, and the homeowner is the secondary insured. He said banks place all business with one insurer. He also asked whether the industry has any evidence that more companies have exited the market recently than have entered. Mr. Levine said loss ratios can be low in a normal year, but they may be much higher in years with catastrophes. He said the group should keep this in mind if there is consideration given to a minimum loss ratio. Mr. Lee said Florida has not seen a major catastrophe in 10 years, but even so, lender-placed loss ratios are lower than those for homeowners policies. Mr. Altmaier said the summary should describe what years are associated with the loss ratios. Birny Birnbaum (Center for Economic Justice CEJ) said the time period used was 2004 2012. He said average loss ratios for homeowners was 60% 65%, and the average for lender-placed insurance was approximately 25%. He said the United States did experience catastrophes during this time, including Superstorm Sandy. He said lender-placed insurers cover flood, while homeowners insurers do not, yet lender-placed insurers still had lower loss ratios. Jim Novak (QBE) said the summary accurately characterizes the testimony of the industry. Mr. Birnbaum said reverse competition describes a market structure and is defined in the Credit Personal Property Insurance Model Act (#365). He said under this structure, consumers exert no market power on price. He said competition for the referrer s business drives up the price of insurance. He said the lender-placed insurance market is textbook reverse competition. Mr. Lee said in Florida, personal property and liability are options under a lender-placed insurance policy. Mr. Birnbaum said that is not really force-placed insurance because in that case, the consumer is making an affirmative decision to opt-in to that coverage. Mr. Lee pointed out that the current Model #395 does not apply to real property. Mr. Novak asked how reverse competition applies to lender-placed insurance since the consumer does have the choice to maintain insurance coverage. He said if a consumer does not comply with a contractual obligation, he or she should not have a say in insurance. He said there were more than a dozen competitors in the industry 20 years ago, and now there are two or three major writers. Mr. Lee said consumers have limited choices. He said the financial institution chooses the insurance, so the market does not exhibit normal competition. He said there have only been three major writers for several years. 2015 National Association of Insurance Commissioners 1

Attachment -- Property and Casualty Insurance (C) Committee 8/17/15 Mr. Novak said the mortgage credit crisis was not related to lender-placed insurance, and lender-placed insurance did not force people into default. He said the major causes of mortgage defaults were unemployment, health insurance issues and divorce. Mr. Lee said overpriced lender-placed insurance is a contributor to defaults. Mr. Novak said the default comes before lender-placed insurance is placed. Mr. Birnbaum said reverse competition does not have to do with the borrower s obligation under the mortgage contract. In a normal market, insurers compete on price. He said the lender-placed insurance market competes on providing consideration to the referrers of the business. He said there is a need for regulators to have oversight over pricing. Mr. Birnbaum said the causes of default are not before this Working Group. He said the Consumer Financial Protection Bureau (CFPB) found unnecessary placements by the lender-placed insurers. Mr. Levine asked how insurance regulators should deal with bad actions made by lending institutions. Mr. Altmaier said the Working Group may wish to look at Florida consent orders. Mr. Birnbaum said Florida and New York have prohibited lender-placed insurers from entering into commission arrangements with servicer-affiliated agents and from entering into captive reinsurance agreements with affiliates of the servicers. He said regulators can prohibit lender-placed insurers from engaging in practices in conjunction with servicers. He also said New York made findings that reverse competition existed. Mr. Altmaier said the New York regulation that was promulgated in January will be distributed to the Working Group. 3. Discussed the Potential Approaches to Revisions to Model #375 Mr. Altmaier said the Working Group will look at what actions states have taken since 2012. He said these actions should be analyzed, and then each section of Model #375 should be reviewed to determine if the model is in line with the key takeaways from the public hearing. He said he thought the rates section of Model #375 would get significant attention. Ms. Dwyer said Model #375 seems to exclude lender-placed insurance on real property, and she asked what the history was of this exclusion. Mr. Lee said Model #375 was originally meant for lender-placed auto. He said the Working Group would need to decide whether it wants to add references to property and flood. Mr. Birnbaum said the NAIC had a committee in the mid-1990s that looked at credit insurance, and it first focused on credit property insurance. He said the Credit Insurance Experience Exhibit was revised in 2004 to include home and auto. Mr. Novak agreed and said there were some discussions over real property at the time, but it was not added. Ms. Dwyer asked whether this would be the first time the NAIC considered adding real property to Model #375. Mr. Altmaier said the Working Group would need to decide whether to expand the model to real property and whether other changes are needed. Mr. Lee pointed out that private lender-placed flood insurance exists. Mr. Birnbaum said the Working Group should consider whether to recommend withdrawing the model or working on it. He said the model is adopted in only three states. He said the model is deficient and conflicts with actions taken in Florida and New York. Mr. Laucher said the Working Group may need to retain generic language in the model and then create subsections for different types of coverage. David Cleff (State National Insurance Companies) said his company writes lender-placed auto insurance and has used Model #375 as a framework. He said the Working Group should consider whether there is a need to withdraw the model completely. Mr. Levin said there could be separate acts. Ms. Dwyer recommended the Working Group begin by looking at the New York regulation. Mr. Altmaier agreed as he thinks New York is the only state to take this kind of action. He also asked individuals to send in any other actions they know that have been taken by states. Having no further business, the Creditor-Placed Insurance Model Act (C) Working Group adjourned. W:\National Meetings\2015\Summer\Cmte\C\Creditor Placed Ins Model Review\8-6 CreditorPlacedWG min.docx 2015 National Association of Insurance Commissioners 2

2015 Summer National Meeting Chicago, Illinois CROP INSURANCE (C) WORKING GROUP Saturday, August 15, 2015 2:00 3:00 p.m. Meeting Summary Report The Crop Insurance (C) Working Group met Aug. 15, 2015. During this meeting, the Working Group: 1. Adopted its Spring National Meeting minutes, which included: hearing updates from the Risk Management Association (RMA) and the National Crop Insurance Services (NCIS). 2. Heard a presentation from the Independent Insurance Agents and Brokers of America, Inc. (IIABA). The IIABA provided the agent and broker perspective concerning the current state of the crop program, the impact of the Standard Reinsurance Agreement (SRA) on agents and brokers and the education initiatives of the IIABA on reducing exposures relative to errors & omissions coverage associated with crop insurance placement. 3. Discussed a referral from the Statutory Accounting Principles (E) Working Group regarding SSAP No. 78 Multiple Peril Crop Insurance. The issue relates to a provision in the farm bill that allows farmers to pay premiums after the exposure period. SSAP No. 78 Multiple Peril Crop Insurance may need to be updated to clarify and define the due dates and terms included in the 2012 farm bill revisions. 4. Heard an update on federal activities. Brooke Stringer (NAIC) provided an update to the Working Group regarding the U.S. Department of Agriculture s (USDA) new crop insurance coverage option that provides producers with coverage against an unexpected decrease in their operating margin, the expansion of the USDA crop insurance coverage for fruit and nut producers beginning in 2016 and the grant money available through the USDA for education programs in states with low levels of federal crop insurance participation and availability. W:\National Meetings\2015\Summer\Summaries\Final Summaries\CropWG.docx 2015 National Association of Insurance Commissioners