The Business Council supports S.3513/A.6131 that makes permanent the 2011 commercial modernization reforms that expanded the types of insurance which may be written without the Department's prior approval of rates and forms when sold to large commercial policyholders.
This legislation also extends for two years the minimum surplus to policyholder ratio required of medical malpractice insurers, from December 31, 2016 to December 31, 2018 and extends the required amount of time for an insurer to file a policy form for informational purposes with the superintendent from three business days to fifteen business days after first delivery of the policy.
The past four years have proven the commercial modernization reforms are a success and should be made permanent. The added regulatory flexibility the reforms have given to large commercial policyholders and their insurance carriers has made it easier to do business in the State of New York.
While the reforms have been a success overall, the informational policy filings that must be made within three days after the first delivery of the policy remains a significant barrier to insurers looking to take advantage of the new reforms. In addition, these filings are of little value to the department of Financial Services when made within the current time frame. We believe extending the time frame these informational filings must be made from three days to fifteen days will add even more regulatory flexibility to companies doing business in New York.
For these reasons, The Business Council supports S.3513/A.6131.