In addition to the cancel/rewrite or endorse question, below are two additional questions the Department was able to answer for us in the early stages as the law is being digested by DIFS.
Is July 1, 2020 realistic for all the filings to be submitted, reviewed, approved, and implemented … and if not, will a delay in implementation be required?
DIFS assured MAIA they will have “all hands on deck” to approve and review filings. They are building a checklist for the companies to know exactly what they need to submit to the Department to get their filings approved timely. It’s unclear exactly when that checklist will be ready for the companies, but fall was mentioned during our meeting with DIFS.
Regardless, the new law changes the filling system in the state for personal auto insurance from “file and use” to “file and approve.”
states that the plan has to be on file with the department 90 days prior to being effective. The Director has the ability to waive part of the waiting period. However, companies are required to have their filings submitted no later than early April to meet the 90-day window. We will keep you posted as the filing process begins.
As for delaying the implementation date, that seems unlikely to happen. The Legislature would have to change the effective date and they have given no such indication. DIFS is operating and planning on being ready July 1, 2020.
Will there be a universal form for BI Residual Liability and PIP Choice?
The new law only requires DIFS to provide the BI Residual Liability Form and assigns the task to the Department to approve company designed PIP choice related forms. DIFS shared with MAIA that they agreed to “draft all forms” for uniformity and clarity for the consumer. Carriers are encouraged
to adopt the uniform language but not required to do so. Again, we encourage you to have conversations to see if your carriers plan to adopt the DIFS recommended uniform language.