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2019 | OriginalPaper | Buchkapitel

Transparency in the Insurance Contract Law in the United States

verfasst von : Aviva Abramovsky, Peter Kochenburger

Erschienen in: Transparency in Insurance Contract Law

Verlag: Springer International Publishing

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Abstract

In the United States, a mix of government regulation and common law decisions govern insurance contracts, and “transparency” in this context does not have a fixed meaning. There are not the sharp distinctions between public and private law that exist in many other jurisdictions (particularly in civil law countries). This is especially true in insurance, where laws regulating insurance contracts are typically a mix of specific government interaction—statutes, regulations, and regulatory notices and bulletins—and the common (“judge-made”) law. For these reasons, transparency standards for insurance agreements are best understood as including both access to essential information about the contract—the cost, forms, terms, endorsements, etc.—and disclosure and other regulatory requirements that support actual knowledge by the parties entering into the insurance agreement and consumer certainty of what coverage is provided.

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Fußnoten
1
For occurrence-based policies. E.g., Aetna Casualty & Surety Co. v. Murphy, 538 A.2d 219 (Conn. 1988). The majority of states do not apply a prejudice requirement to claims-made policies.
 
2
N.Y. Insurance Law § 3420 (a)(5) (McKinney).
 
3
As of 2017, the U.S. accounted for 38.5% of the world’s premium volume; China has surpassed Japan and is now second with 9.5%. National Association of Insurance Commissioners, Financial Data Repository. http://​www.​naic.​org/​documents/​cipr_​stats_​top_​50_​worldwide_​insurance_​markets.​pdf. Accessed 27 April 2019. This amount includes health insurance premiums.
 
4
Although the federal government has played a major role in funding health insurance and health care since the 1960s with the creation of the Medicare and Medicaid programs, states have still been largely responsible for regulating health insurance, though with significant limitations over employer-provided health care insurance. The advent of the Affordable Care Act (Public Law 111-148 (2010) put the federal government into direct regulation of healthcare insurance and created an even more complex interplay between federal and state regulatory authority. Recent Congressional and Executive branch dismantling of many elements of the Affordable Care Act adds additional uncertainty to this area.
 
5
In this article, we focus on transparency in property-casualty and life insurance markets and will not review health insurance, which as noted, supra, has a different regulatory structure in the United States and overall is less relevant for international comparisons.
 
6
The territories of American Samoa, Guam, Northern Mariana Islands, and the U.S. Virgin Islands.
 
7
For example, as of March 2019, 15 of the 56 state (and territorial) insurance commissioners were new from the previous year. State insurance department personnel, including senior staff, are typically civil servants and often serve for many years.
 
8
See Schwarcz and Schwarcz (2014), pp. 1569, 1578–1580; Thomas (2010), pp. 773, 781–786.
 
9
See Randall (1999), p. 625; French (2019), p. 25.
 
10
Paul v. Virginia, 75 U.S. 168 (1868). In the United States, the federal government’s authority is not plenary but established and limited by the Constitution. Federal regulatory authority over commercial practices is typically located in the Commerce Clause, U.S.C.A. Const. art. I § 8, cl. 3.
 
11
U.S. v. South-Eastern Underwriters Association, 322 U.S. 533 (1944).
 
12
“No Act of Congress shall be construed to invalidate, impair, or supersede any law enacted by any State for the purpose of regulating the business of insurance, or which imposes a fee or tax upon such business, unless such Act specifically relates to the business of insurance.” 15 U.S.C. § 1012(b). The industry remains subject to state antitrust laws, many of which mirror their federal counterparts.
 
13
Congress can remove all doubt as to its intent in specific legislation to regulate insurance simply by so indicating, as for example in the Terrorism Risk Insurance Act, codified as a note to 28 U.S.C. § 1610.
 
14
(2018) Selected International Insurance Issues in the 115th Congress. Congressional Research Service, R44820. https://​fas.​org/​sgp/​crs/​misc/​R44820.​pdf. Accessed 27 April 2019.
 
15
NAIC accreditation standards focus on solvency regulation and has been effective in implementing these standards—all 50 states, Puerto Rico, and the District of Columbia are accredited. https://​www.​naic.​org/​cipr_​topics/​topic_​accreditation.​htm. Accessed 27 April 2019. In contrast, there are some significant differences among the states in market conduct regulation, rate and form review, and other non-solvency related areas.
 
16
For now, the Federal Insurance Office’s only regulatory authority is the ability to pre-empt state laws inconsistent with international treaty obligations related to solvency regulation—although only after completing a daunting administrative process. See 31 U.S.C. § 313.
 
17
Abramovsky and Kochenburger (2016).
 
18
Abramovsky and Kochenburger (2016), pp. 125–126. The Financial Stability Oversight Council (FSOC), another Dodd-Frank regulatory creation, reviews financial institutions—banks and “nonbank financial companies”—to determine if their failure could threaten national financial stability. The Federal Reserve Board has regulatory authority over holding companies FSOC deems systemically significant, along with insurance holding companies that include a federally-insured depository institution. Dodd-Frank Wall Street Reform and Consumer Protection Act. 12 USC 5301 § 113 (2010).
 
19
See U.S. Department of the Treasury. (2019) http://​www.​treasury.​gov/​initiatives/​fsoc/​designations/​Pages/​default.​aspx. Accessed 27 April 2019.
 
20
Legal treatises can play a major role in analyzing and attempting to harmonize the law in insurance, contracts, and many other areas dominated by state common law.
 
21
E.g., Arkansas Code § 23-79-155 (2011); South Carolina Code § 38-61-70 (2011) (held unconstitutional as to retroactive effect only, Harleysville Mutual Ins. Co. v. South Carolina Dept. of Insurance, 736 S.E.2d 651 (S.C. 2012)).
 
22
“[t]he formation of a contract requires a bargain in which there is a manifestation of mutual assent to the exchange and a consideration.” Restatement (Second) of Contracts, § 17. “The fundamental goal of interpreting an insurance policy, as in all contracts, is to carry out the intent of the contracting parties. To discern the parties’ intent, we begin with an examination of the insurance policy language.” Santos v. Metropolitan Property and Cas. Co., 201 A.3d 1243, 1247 (N.H. 2019).
 
23
Consumers would usually receive the declarations page at the time of contracting, which would identify the parties, the type of insurance purchased (e.g., homeowners), the policy limits, and a list of endorsements—by number, but not otherwise identified by name or limitations (additional exclusions).
 
24
See Abraham and Schwarcz (2015).
 
25
Nor is it clear that insurance producers—agents and brokers—would even have up-to-date and accurate copies of the various policy forms their clients are agreeing to (although now presumably at least available to the producer from the insurer’s online resources).
 
26
An Unfair Trade Practice includes “Misrepresentations and False Advertising of Insurance Policies … that misrepresents the benefits, advantages, conditions or terms of any policy.” NAIC Model Unfair Trade Practices Act § 4.A.(1).
 
27
National Association of Insurance Commissioners, https://​www.​naic.​org/​cipr_​topics/​topic_​transparency_​readability.​htm. Accessed 27 April 2019.
 
28
Randall (2007), pp. 107, 124–125; Century Surety Company v. Jim Hipner, LLC, 377 P.3d 784, 789 (Wyo. 2016).
 
29
E.g., the ubiquitous “do you accept the terms and conditions” box with a link to the agreement itself when purchasing/downloading media or other software. In some transactions, consumers have a limited right to cancel or rescind an agreement; for example, there is a three-day right to cancel for residential mortgage refinancing and door-to-door sales.
 
30
Credit Card Agreement Database (2019) Consumer Financial Protection Bureau. https://​www.​consumerfinance.​gov/​credit-cards/​agreements/​. Accessed 27 April 2019; Truth in Lending Act, 15 U.S.C.A. §; 1632 (West); C.F.R. § 1026.58 (2019).
 
31
E.g., California, Maine, Missouri, Nevada, and Oklahoma. For examples, the Missouri Department of Insurance posts the policies for the top ten homeowners and personal automobile insurers: https://​insurance.​mo.​gov/​consumers/​auto/​auto_​policies.​php. Accessed 28 April 2019.
 
32
In contrast, many insurers allow existing policyholders to access their own documents online. See, e.g., Missouri Rev. Statute 379.011 (2014).
 
34
Compact (2019). https://​insurancecompact​.​org/​index.​htm. Accessed 27 April 2019. California, Florida, and New York are not Compact members, although as of spring 2019, New York was considering legislation to join the Compact.
 
35
Specific standards are set out for each product, which in addition to specifying specific policy terms, such as limiting contestability provisions to a two-year maximum, may also restrict the use of certain provisions, such as requiring arbitration in the event of a dispute. See, e.g., Individual Whole Life Insurance Policy Standards: https://​insurancecompact​.​org/​rulemaking_​records/​141204_​individual_​whole_​life_​insurance.​pdf. Accessed 27 April 2019.
 
36
Compact (2019). https://​insurancecompact​.​org/​about.​htm. Accessed 27 April 2019.
 
37
SERFF is a NAIC product administered by the Speed to Market Working Group; its separate advisory board is selected by the NAIC’s Executive Committee. See System for Electronic Rates and Form Filing (2019) About the SERFF. www.​serff.​com. Accessed 27 April 2019.
 
38
Consumers must first locate the SERFF portal on the state insurance department website, click through to SERFF and then select from a series of drop-down menus clearly designed for regulatory specialists rather than as a consumer interface. See SERFF (2019) SERFF Filing Access. www.​serff.​com/​serff_​filing_​access.​htm. Accessed 27 April 2019.
 
39
These standards typically apply to personal lines policies rather than those written for commercial entities, with significant state variation as to which lines of insurance and insurance products are included.
 
40
See, e.g., Conn. Gen. Stat. Ann. § 38a-297, 298. The NAIC Life and Health Insurance Policy Language Simplification Model Act (MDL-575) has similar requirements. NAIC (2019) Products: Technology, Data, and Publications. https://​www.​naic.​org/​prod_​serv_​model_​laws.​htm. Accessed 27 April 2019.
 
41
See, e.g., https://​www.​insurance.​ca.​gov/​01-consumers/​ (California Department of Insurance); https://​www.​statefarm.​com/​insurance (State Farm); https://​www.​burnsandwilcox.​com/​personal/​ (Burns & Wilcox agency based in Michigan); https://​www.​acli.​com/​Consumer-Info (American Council of Life insurers); https://​www.​iii.​org/​insurance-basics (Insurance Information Institute); http://​www.​uphelp.​org/​ (United Policyholders).
 
42
See NAIC (2019) Consumer Index. http://​naic.​org/​index_​consumer.​htm. Accessed 27 April 2019. The NAIC also sponsors “Insure U,” which provides a variety of online resources, including videos, games, smart phone apps, and extensive links to additional information. Insure U (2019) http://​www.​insureuonline.​org/​. Accessed 27 April 2019.
 
43
E.g., Wisconsin Office of the Commissioner of Insurance (2019), https://​oci.​wi.​gov/​Pages/​Consumers/​ConsumerPublicat​ions.​aspx. Accessed 27 April 2019.
 
44
For example, one of the first projects undertaken by the federal Consumer Financial Protection Bureau was to redesign required residential mortgage disclosure forms through this evaluation and testing process, resulting in disclosure forms significantly more likely to contain information consumers needed in more accessible language and format. Kennedy et al. (2012), pp. 1141, 1160–1167.
 
45
New entrants are addressing transparency issues in interesting ways; Lemonade Insurance is one example, discussed several paragraphs on.
 
46
For example, August 6, 2018 presentation by Birny Birnbaum, Professor Brenda Cude and Silvia Yee to the NAIC Consumer Liaison Committee: https://​www.​naic.​org/​meetings1811/​cmte_​conliaison_​2018_​fall_​nm_​materials.​pdf. Accessed 28 April 2019.
 
47
See Section II.4, infra, for a discussion on the utility of consumer disclosures.
 
49
“The term ‘smart disclosure’ refers to the timely release of complex information and data in standardized, machine readable formats in ways that enable consumers to make informed decisions. Smart disclosures will typically take the form of providing individual consumers of goods and services with direct access to relevant information and data sets. Such information might involve, for example, the range of costs associated with various products and services, including costs that might not otherwise be transparent.” https://​www.​data.​gov/​consumer/​smart-disclosure-policy-resources. Accessed 28 April 2019. But see Marotta-Wurgler (2014).
 
50
Texas: https://​www.​opic.​texas.​gov/​residential-property/​compare-policy-coverages/​homeowners. Accessed 28 April 2019. This agency is independent from the Texas Department of Insurance. California: https://​interactive.​web.​insurance.​ca.​gov/​apex/​f?​p=​143:​1. Accessed 28 April 2019.
 
53
Industry and consumer organizations regularly caution individuals not to shop by price alone. https://​www.​iii.​org/​article/​how-to-save-money-on-your-homeowners-insurance (Insurance Information Institute); https://​www.​consumerreports.​org/​car-insurance/​10-tips-to-save-on-car-insurance/​ (Consumers Union). Accessed 28 April 2019.
 
54
Organized in 1923, the American Law Institute describes itself as “the leading independent organization in the United States producing scholarly work to clarify, modernize, and otherwise improve the law.” www.​ali.​org. The ALI is composed of judges, academics, and practicing attorneys through a membership nomination process.
 
55
For example, courts frequently cite the Restatement 2nd of Contracts in insurance contract disputes.
 
56
This Restatement provides an in-depth analysis of common law doctrines and principles in insurance, along with “black letter” rules that harmonize these various approaches. The Restatement has encountered significant industry opposition, which continues through the writing of our article.
 
57
For example, these three treatises are frequently cited: Stempel and Knutsen (2018); Ostrager and Newman (2018); Windt (2019 update).
 
58
Couch on Insurance, 3d (Thomson Reuters); New Appleman on Insurance Law (LexisNexis).
 
59
E.g., ABA Tort, Trial & Insurance Section, https://​www.​americanbar.​org/​groups/​tort_​trial_​insurance_​practice/​. Accessed 28 April 2019.
 
60
These articles are most easily accessed through SSRN, Westlaw, LexisNexis, or similar legal databases. See alsohttps://​library.​law.​uconn.​edu/​insurance-law; http://​guides.​ll.​georgetown.​edu/​c.​php?​g=​363473&​p=​2455742.
 
61
“Lemonade Insurance Company is a property and casualty insurance company that is transforming the very business model of insurance. By injecting technology and transparency into an industry that often lacks both, we’re creating an insurance experience that is fast, affordable and hassle free.” Lemonade (2019) Service FAQs. https://​www.​lemonade.​com/​faq#service. Accessed 27 April 2019. Also https://​www.​lemonade.​com/​transparency.
 
62
Lemonade (2019) Terms of Service. https://​www.​lemonade.​com/​terms-of-service. Accessed 27 April 2019. The transformation does not yet include their policy forms, which utilize standard ISO language.
 
63
E.g., Minimum Provisions for Automobile Liability Insurance, Connecticut Administrative Code §§ 38a-334-1 to 334-8.
 
64
E.g., Kansas Statutes Annotated 40-420 (2017): “No life insurance company authorized to transact the business of insurance in this state shall issue or deliver in this state any policy of life insurance other than industrial insurance, annuities and pure endowments with or without return of premiums or of premiums and interest unless the same shall contain in substance the following provisions:…”
 
65
E.g., Cal. Ins. Code § 11654 (2018): “Every such contract or policy shall contain a clause to the effect that the insurer will in all things be bound by and subject to the orders, findings, decisions or awards rendered against the employer under the provisions of the law imposing liability for compensation, subject to the provisions, conditions and limitations of the policy. The insurance contract shall govern as between the employer and insurer as to payments by either in discharge of the employer’s liability for compensation.”
 
66
E.g., New York Ins. Law § 3420(a) (McKinney’s).
 
67
E.g., GA law. In December 2018, the NAIC adopted an advisory bulletin prohibiting the use of pre-dispute mandatory arbitration clauses and choices of law and venue provisions in personal lines policies. NAIC (2019) Legal Bulletins. https://​naic.​org/​legal_​bulletins.​htm. Accessed 27 April 2019.
 
68
E.g., New York Ins. Law § 3404 (McKinney’s).
 
69
In contrast to the European Union, regulating insurance rates is still a commonly used tool in the United States, particularly for residential and automobile insurance, health insurance, and for required insurance products such as workers’ compensation insurance. For individual state requirements, see NAIC (2019) Industry Rates Forms Filing Checklist. https://​www.​naic.​org/​industry_​rates_​forms_​filing_​checklists.​htm. Accessed 27 April 2019. In this article we focus on form rather than rate regulation.
 
70
Such as ISO, formerly known as the Insurance Services Office, and now part of Verisk: https://​www.​verisk.​com/​. Accessed 27 April 2019.
 
71
E.g., Oregon Statute § 743.019—requires policy forms and endorsements to be filed with the Director, with the requirement that they be approved or disapproved within 30 days. This statute also includes numerous exceptions, largely for commercial insurance products.
 
72
A “file and use” system requires insurers to file policy forms with the state regulator concurrent with introducing them into the market, but does not require advance regulatory approval. “Use and file” allows insurers to utilize new forms prior to filing them with the regulator, though filing is still required. The Federal Insurance Office’s 2013 report “How to Modernize and Improve State Insurance Regulation in the United States,” discusses state rate and form regulation, pp. 48–55, available at https://​www.​treasury.​gov/​initiatives/​fio/​reports-and-notices/​Pages/​default.​aspx. Accessed 6 May 2019.
 
73
“Commercial Lines Deregulation is having a Moment,” Insurance Journal, January 16, 2018.
 
74
The Court continued “ …The policies are prepared by the experts of the companies, they are highly technical in their phraseology, they are complicated and voluminous—the one before us covering thirteen pages of the transcript—and in their numerous conditions and stipulations furnishing what sometimes may be veritable traps for the unwary. … The courts, while zealous to uphold legal contracts, should not sacrifice the spirit to the letter nor should they be slow to aid the confiding and innocent.” Raulet v. Northwestern Insurance Co., 107 P. 292, 298 (Cal. 1910).
 
75
“Even when the standard form contract is available, very few people read it. Empirical work is scant, perhaps because of the folk knowledge that no one reads boilerplate. Still, some direct as well as indirect evidence suggests that almost no consumers read boilerplate, even when it is fully and conspicuously disclosed.” Ben-Shahar and Schneider (2011), pp. 647, 671—the authors then describe one such study. See also, Schwarcz (2017), pp. 1457, 1458.
 
76
Professor Daniel Schwarcz has written persuasively on this issue. Id. See also Fung et al. (2004), pp. 13, 21, available at https://​www.​hks.​harvard.​edu/​publications/​political-economy-transparency-what-makes-disclosure-policies-effective.
 
77
A 1905 treatise on the New York Standard Fire Insurance Policy stated, “The value of a Standard Form of Policy to the insured lies chiefly in the fact that now there is only one form of policy used in a state by all Companies, instead of numerous conflicting forms issued by many companies. Prior to the use of a standard form of policy it was difficult to determine when the property of the insured was protected and still more difficult to arrive at an adjustment in case of loss.” Darrach (1905). These requirements are litigated and upheld today. See, e.g., Streit v. Metropolitan Casualty Ins. Co., 864 F.3d 770, 773 (7th Cir. 2017) (“All policies written in the State of Illinois must conform to the requirements of the Standard Policy”).
 
78
Insurance Law, Sec. 6.6 Regulation of Defenses Based on Warranty, Representation, or Concealment in Keeton, Widiss and Fischer (2d Edition); ALPS Prop. & Cas. Ins. Co. v. McLean & McLean, PLLP, 425 P.3d 651, 657, reh’g denied (Sept. 18, 2018).
 
79
Insurance Law, Sec. 6.6 Regulation of Defenses Based on Warranty, Representation, or Concealment in Keeton, Widiss and Fischer (2d Edition); ALPS Prop. & Cas. Ins. Co. v. McLean & McLean, PLLP, 425 P.3d 651, 657, reh’g denied (Sept. 18, 2018).
 
80
Insurance Law, Sec. 6.6 Regulation of Defenses Based on Warranty, Representation, or Concealment in Keeton, Widiss and Fischer (2d Edition); ALPS Prop. & Cas. Ins. Co. v. McLean & McLean, PLLP, 425 P.3d 651, 657, reh’g denied (Sept. 18, 2018).
 
81
“For example, if the insured warrants as a condition of coverage that a certain fact exists, coverage may turn on the actual existence of that fact; on the other hand, if the statement is a representation not a warranty, coverage may turn not only on the accuracy of the representation but in addition, whether the insured ‘had no present knowledge of the facts sought or failed to appreciate the significance of the information related to him…’ such that the insured could not appreciate or know that the fact represented was incorrect.” Keaton, fn 230.
 
82
“Instead of thinking about ‘assent’ to boilerplate clauses, we can recognize that so far as concerns the specific, there is no assent at all. What has in fact been assented to, specifically, are the few dickered terms, and the broad type of the transaction, and but one [thing] more. That one thing more is a blanket assent (not a specific assent) to any not unreasonable or indecent terms the seller may have on his form, which do not alter or eviscerate the reasonable meaning of the dickered terms. The fine print which has not been read has no business to cut under the meaning of those dickered terms which constitute the dominant and only real expression of agreement, but much of it commonly belongs in.” Parton, 730 S.W.2d at 637(quoting K. Llewellyn, The Common Law Tradition: Deciding Appeals § 370 (1960) (emphasis in original).
 
83
Insurance Law, Sec. 6.6 Regulation of Defenses Based on Warranty, Representation, or Concealment in Keeton, Widiss and Fischer (2d Edition); ALPS Prop. & Cas. Ins. Co. v. McLean & McLean, PLLP, 425 P.3d 651, 657, reh’g denied (Sept. 18, 2018).
 
84
Insurance Law, Sec. 6.6 Regulation of Defenses Based on Warranty, Representation, or Concealment in Keeton, Widiss and Fischer (2d Edition); ALPS Prop. & Cas. Ins. Co. v. McLean & McLean, PLLP, 425 P.3d 651, 657, reh’g denied (Sept. 18, 2018).
 
85
N.Y. Ins. Law § 3106 (2019). See also Insurance Law, Sec. 6.6 Regulation of Defenses Based on Warranty, Representation, or Concealment in Keeton, Widiss and Fischer (2d Edition); ALPS Prop. & Cas. Ins. Co. v. McLean & McLean, PLLP, 425 P.3d 651, 657, reh’g denied (Sept. 18, 2018).
 
86
See, e.g., N.Y. Ins. Law § 3203(a)(3) (2019) (“All life insurance policies, except as otherwise stated herein, delivered or issued for delivery in this state, shall contain in substance the following provisions, or provisions which the superintendent deems to be more favorable to policyholders … that the policy shall be incontestable after being in force during the life of the insured for a period of two years from its date of issue ….”).
 
87
See NAIC’s Center for Insurance Policy Research, https://​www.​naic.​org/​cipr_​topics/​topic_​big_​data.​htm. Accessed 29 April 2019; Helfand (2017); Swedloff (2014), p. 339; Kochenburger (2018), available at https://​www.​insurancebusines​smag.​com/​us/​opinion/​the-dark-side-of-big-data-115234.​aspx.
 
88
See generally Ericson et al. (2003) (explaining the regulatory roles of insurance).
 
89
Employing credit scores as a risk classification is more properly described as “old big data,” as they have been used since the mid-1990s in personal lines policies. Nevertheless, it provides a good example of the issues that arise when risk correlation appears separated from “causation,”—at least in the public’s view. See Center for Economic Justice, The Challenges and Opportunities of Big Data: Reforming State-Based Insurance Regulation in the 21st Century, presentation to the Federal Advisory Committee on Insurance, January 5, 2017. Available at https://​www.​treasury.​gov/​initiatives/​fio/​Pages/​faci.​aspx.
 
90
For example, an individual’s credit score cannot be the sole factor used in underwriting the policy, e.g., Connecticut General Statutes § 38a-686 (regulatory bulletin PC-69 March 17, 2011). A small number of states ban its use in specific lines altogether, such as Hawaii (Haw. Rev. Stat. Ann. § 431:10C-207 (West)) and California (auto—California Code of Regulations 2360.0(b)).
 
91
The Federal Fair Credit Reporting Act, 15 U.S.C.A. § 1681, governs creditor and insurer use of specific types of data, including credit reports, and includes consumer notification and correction rights. However, this Act does not apply to much of the information now utilized, such as data gleaned from social media use.
 
92
The NAIC’s Property and Casualty Model Rate and Policy Form Law Guideline (Guideline 1776) has been adopted—and often modified—by most jurisdictions in the United States.
 
93
“[R]egulators must rely upon insurers to present accurate and complete information on indicated rates and the adjustments to arrive at selected rates. Regulators do not currently have the data necessary for an independent evaluation of most of the insurer modeling and calculations.” NAIC’s Casualty Actuarial and Statistical (C) Task Force Price Optimization White Paper, p. 10 (adopted April 6, 2016), available at https://​naic.​org/​cmte_​c_​catf.​htm. Accessed 16 May 2019; Krafcheck (2016), available at http://​www.​milliman.​com/​insight/​2016/​Predicting-the-unpredictable-Considerations-for-rate-filing-support-when-implementing-predictive-models/​. Accessed 15 May 2019.
 
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Metadaten
Titel
Transparency in the Insurance Contract Law in the United States
verfasst von
Aviva Abramovsky
Peter Kochenburger
Copyright-Jahr
2019
Verlag
Springer International Publishing
DOI
https://doi.org/10.1007/978-3-030-31198-8_28