Executive summary
The U.S. insurance regulatory environment is complex and difficult to navigate, even for experienced professionals. Modern analytics can be applied to publicly available insurance product filing data to produce actionable regulatory insurance intelligence that demystifies the insurance regulatory world. A key metric, called “rate filing average days to approval,” is calculated from publicly available data and can aid filers like insurance companies, managing general agents, and others in decision-making and formulating insurance product rollout schedules. This paper discusses rate filing average days to approval for the personal auto and homeowners lines of business (LOB) in several states, how it is determined, and how it can be used to maximize resources and reduce overall time to market.
This paper has been updated from the version published on September 4, 2024. This updated version contains filings through 2024 Q4 and highlights a different set of states.
What is rate filing average days to approval and why is it important?
When developing or revising insurance products it is important to recognize that the natural and man-made hazards to which people and property are exposed (e.g., wildfires, hurricanes, sinkholes) differ by state, as do the laws, regulations, filing requirements and internal Department of Insurance (DOI) rules that are not published (desk rules) with which companies need to comply to receive state regulatory approval. In addition, the unique political, legal, social, economic, and other issues present in each state (e.g., potential claims fraud, affordability challenges, a recent catastrophic event) influence what each state DOI focuses on during its regulatory review. All these factors, including DOI staffing, resources, and outsourcing of reviews, contribute to regulatory review times that significantly vary by state and by LOB.
Rate filing average days to approval are estimates of the average number of days that it takes for a rate filing to be approved by a state DOI once it has been submitted for review. One of the most important use cases for state approval data is to determine where and when to launch new insurance products or to facilitate multistate changes to existing products. To best utilize the rate filing average days to approval metric, a filer must first consider the goals of its product filing.
For example, if the company’s goal is to launch a new program as quickly as possible, then the company can identify which states are generally the quickest to complete their reviews. Filing in these states first would allow the company more time to start collecting exposure and loss experience data once the product has gone live. This data can then be used to fine-tune the product before entering more rigorously regulated states. Filing a tested and proven product in states with longer expected approval times can save the company time in the future because any adjustments to the new program filing are subject to the same longer state regulatory approval times. In addition to having a more tested and proven product before filing in states with longer approval times, a company filing first in states with shorter approval times will be able to collect policy premiums earlier and test whether its insurance product is attracting the targeted policyholders. This could allow companies, especially startups, the opportunity to better forecast whether their insurance programs will be profitable and, if so, what funds are needed to pursue the next phase of filings.
Alternatively, if the company’s goal is to launch a new program across all states at approximately the same time, it may choose to prioritize filings for states that generally have longer review times. This allows regulators in these states more time to complete their reviews, while the remaining state filings are being prepared and submitted for approval. Further, states that have longer review times are generally more rigorously regulated and require more filing support, so preparing additional support for the first several states can lead to efficiencies when filing in future states. These more rigorous states may also require changes in the program that can be implemented countrywide. Therefore, by starting in the rigorous states, the company may have the option to adjust its countrywide filing material instead of having state-specific filing material. A consistent countrywide product would make implementing the insurance product easier for the insurance company.
It is important that filers are aware of and stay up to date on state-specific laws, regulations, guidelines, and other rules enforced by each DOI so that the filers can prepare filings that meet each DOI’s expectations. This preparation facilitates more efficient regulatory filing reviews by the DOIs, informs company go-to-market strategies, and aligns stakeholder expectations. Submitting filings that overlook state-specific requirements may result in more DOI questions (in the form of objections) or outright disapproval of the filing, which will extend regulatory review times and challenge the company’s overall project timelines and goals. Overlooking state requirements may also result in future fines resulting from market conduct examinations finding noncompliance with a state requirement even after a filing has been approved.
Analysis results: Private passenger auto rate filings
The following heat maps summarize the results of the regulatory filing analysis. Figure 1 is a heat map of the average days to approval for PPA rate filings approved from 2019 through 2024, for selected states. The states with average days to approval less than the countrywide average are displayed in green, while the states with higher average days to approval are shown in orange.
Figure 1: Private passenger auto rate filing average days to approval by state
The table in Figure 2 below summarizes PPA rate filing average days to approval for each selected state by calendar year in which the rate filing was approved. The “Countrywide” row includes all states across the country, including those not shown in each figure, and is used to calculate how many days each state differs from the countrywide (CW) average.
Figure 2: Private passenger auto rate filing average days to approval by approval year
| State | 2019 | 2020 | 2021 | 2022 | 2023 | 2024 | Avg | Difference from CW |
|---|---|---|---|---|---|---|---|---|
| Alaska | 48 | 33 | 76 | 78 | 65 | 61 | 60 | 0 |
| Arkansas | 18 | 13 | 16 | 26 | 30 | 26 | 22 | -38 |
| California | 219 | 231 | 197 | 206 | 245 | 269 | 242 | 182 |
| Connecticut | 32 | 36 | 42 | 76 | 85 | 81 | 58 | -2 |
| Delaware | 71 | 63 | 84 | 79 | 81 | 89 | 78 | 18 |
| District of Columbia | 120 | 139 | 111 | 124 | 154 | 208 | 148 | 88 |
| Georgia | 51 | 49 | 66 | 65 | 66 | 109 | 68 | 8 |
| Hawaii | 133 | 74 | 104 | 165 | 128 | 231 | 130 | 70 |
| Idaho | 57 | 23 | 21 | 9 | 36 | 76 | 38 | -22 |
| Illinois | 12 | 9 | 16 | 15 | 52 | 32 | 24 | -36 |
| Iowa | 38 | 47 | 91 | 49 | 65 | 66 | 58 | -2 |
| Kansas | 24 | 27 | 39 | 37 | 44 | 41 | 35 | -25 |
| Louisiana | 43 | 38 | 33 | 47 | 30 | 14 | 34 | -26 |
| Maine | 33 | 19 | 48 | 51 | 60 | 60 | 45 | -15 |
| Michigan | 20 | 63 | 39 | 68 | 63 | 48 | 50 | -10 |
| Minnesota | 65 | 54 | 81 | 52 | 132 | 59 | 77 | 17 |
| Missouri | 74 | 120 | 105 | 54 | 36 | 40 | 71 | 11 |
| Nebraska | 33 | 19 | 8 | 19 | 14 | 22 | 19 | -41 |
| New Hampshire | 36 | 23 | 37 | 37 | 35 | 35 | 33 | -27 |
| New Jersey | 49 | 44 | 47 | 85 | 121 | 117 | 81 | 21 |
| North Carolina | 17 | 18 | 23 | 12 | 12 | 21 | 17 | -43 |
| North Dakota | 49 | 21 | 25 | 37 | 48 | 47 | 38 | -22 |
| Oklahoma | 91 | 47 | 33 | 25 | 28 | 27 | 39 | -21 |
| Pennsylvania | 24 | 19 | 29 | 33 | 45 | 52 | 33 | -27 |
| South Carolina | 32 | 32 | 30 | 34 | 53 | 63 | 41 | -19 |
| South Dakota | 5 | 12 | 8 | 9 | 12 | 17 | 11 | -49 |
| Texas | 87 | 91 | 185 | 125 | 102 | 136 | 117 | 57 |
| Utah | 31 | 32 | 45 | 40 | 38 | 35 | 37 | -23 |
| Vermont | 68 | 70 | 71 | 116 | 148 | 111 | 97 | 37 |
| West Virginia | 31 | 20 | 25 | 50 | 44 | 24 | 33 | -27 |
| Wyoming1 | 19 | 14 | 15 | N/A | N/A | N/A | 16 | -44 |
| Countrywide | 49 | 48 | 71 | 57 | 64 | 69 | 60 |
Analysis results: Homeowners rate filings
Figure 3 is a heat map of the average days to approval for HO rate filings approved from 2019 through 2024, for a different set of selected states.
Figure 3: Homeowners rate filing average days to approval by state
The table in Figure 4 below summarizes rate filing average days to approval for each selected HO state by calendar year in which the rate filing was approved and includes the difference of approval days from the countrywide average.
Figure 4: Homeowners rate filing average days to approval by approval year
| State | 2019 | 2020 | 2021 | 2022 | 2023 | 2024 | Avg | Difference from CW |
|---|---|---|---|---|---|---|---|---|
| Colorado | 330 | 570 | 636 | 381 | 272 | 141 | 368 | 303 |
| Delaware | 88 | 108 | 79 | 57 | 67 | 80 | 80 | 15 |
| District of Columbia | 166 | 114 | 132 | 152 | 174 | 141 | 148 | 83 |
| Kansas | 31 | 36 | 42 | 37 | 39 | 45 | 38 | -27 |
| Maine | 42 | 29 | 35 | 52 | 52 | 72 | 47 | -18 |
| Missouri | 80 | 91 | 83 | 50 | 27 | 37 | 60 | -5 |
| New Jersey | 52 | 60 | 138 | 124 | 130 | 135 | 109 | 44 |
| Nevada | 65 | 68 | 53 | 87 | 130 | 191 | 101 | 36 |
| North Carolina | 21 | 30 | 28 | 17 | 11 | 33 | 23 | -42 |
| Ohio | 33 | 25 | 28 | 35 | 35 | 52 | 35 | -30 |
| Oklahoma | 29 | 21 | 26 | 36 | 26 | 28 | 28 | -37 |
| South Carolina | 30 | 49 | 46 | 44 | 57 | 100 | 53 | -12 |
| Texas | 96 | 113 | 117 | 83 | 88 | 161 | 107 | 42 |
| Virginia | 40 | 27 | 33 | 25 | 62 | 52 | 42 | -23 |
| West Virginia | 47 | 37 | 14 | 29 | 38 | 34 | 32 | -33 |
| Countrywide | 51 | 60 | 72 | 63 | 65 | 78 | 65 |
The averages for each approval year may be used to understand whether a state is trending toward shorter or longer review times. Additionally, each state’s difference from countrywide may be used to indicate whether a state generally takes more time than average, illustrated by a positive value, or less time than average, illustrated by a negative value.
Conclusion
The data presented in Figures 1 through 4 can be used to estimate timelines and inform a program filing schedule for product changes or expansion into new states or LOBs. For example, if the filer’s goal is to implement a rate change across several states at the same time, without access to the information in the figures above, then the insurer could unknowingly start to submit filings in faster-to-review states. The rate filings in these states are likely to be approved relatively quickly, while the submission of filings in longer-to-review states would just be starting. This could result in the longer-to-review states taking additional time to get approved instead of using more efficient schedules.
Instead, the filer could review the data in the figures and decide to roll out the rate change across longer-to-review states before the faster-to-review states so that review results occur simultaneously. Further, the longer-to-review states are often the larger premium volume states, so this approach may also move toward the company’s profitability targets quicker. It is important to realize this strategy may not work best for all companies, so considering a company’s goals is crucial when selecting the order of states to file in.
The data presented in Figures 1 through 4 can also be used to see whether a company should encourage legislative change to the rate filing approval process. Long approval times can be detrimental not only for companies trying to enter the insurance market but also for existing companies that are not able to adequately adjust their rates after their prior rate filing has been approved.
While it is possible that individual filing reviews could be longer or shorter than the historical averages, having information to optimize the order of filing submissions can be used by filers to gain efficiencies, reduce time to market, respond to market demands and evolving risk, and provide a competitive advantage. The information about filing review times can also be used to inform company stakeholders so that they can align schedules and expectations for a successful implementation that supports company growth, profitability, budgeting, resource allocation, and other initiatives. Working with experts who can help optimize a company’s insurance product filing schedule may help the company achieve its premium volume, profitability, and other goals more efficiently and quickly.
1 States marked with “N/A” days to approval did not have any PPA rate filings.
2 PPA filings included the following types of insurance: personal auto combinations, private passenger auto, motorcycle, recreational vehicle (RV), and other auto. Starting with 2024Q4 release, symbol filings and model rule filings are excluded.
3 HO filings included the following types of insurance: homeowners sub-TOI combinations, condominium, mobile homeowners, owner-occupied, tenant, and other homeowners. Starting with 2024Q4 release, mobile physical damage only filings and model rule filings are excluded.
4 Each DOI has its own way of indicating that filings are approved for use. The following are examples of disposition statuses that are considered approved for the purposes of this analysis: acknowledged, approved, file and use, filed, recorded effective as submitted, reviewed, etc. The information collected and the average days to approval calculation was the same across all filings, regardless of whether the filing was submitted for prior approval, file and use, or use and file.