AITC Submits Comments on NAIC Model Unfair Trade Practices Act (“Rebates”)
November 18, 2020
Commissioner Jon Godfread
National Association of Insurance Commissioners
444 North Capitol Street NW, Suite 700
Washington, DC 20001
Attention: Denise Matthews, Director, Data Coordination and Statistical Analysis
Commissioner Godfread:
Thank you for the opportunity to provide public comments on the NAIC’s Section 4(H) of NAIC Model Unfair Trade Practices Act (“Rebates”). This comment letter is submitted on behalf of the American InsurTech Council (“AITC”). AITC is the independent voice for insurTech’s, traditional insurance companies and agencies, and other stakeholders sharing common goals and objectives before state insurance regulators and the National Association of Insurance Commissioners, federal and state legislators, other policymakers, the media and the general public.
The proposed changes to NAIC’s Section 4(H) of NAIC Model Unfair Trade Practices Act reflect an important step forward. Insurers and their partners continue to work on using technology to improve the health, life, and well-being of their clients. While the statement may seem to be an overstatement, it is important to understand that increasingly technology assists in aligning consumer and insurer interests. Life and health insurers are using technology to help their client’s live longer and healthier lives. Auto insurers have worked to ensure their drivers and their cars are safer. Homeowner insurers help consumers monitor their house to mitigate damage before it becomes serious.
In short, these changes reflect what has been happening in the insurance market and appreciate regulators willingness to think about these issues in new ways. But these changes are just the first step.
In some ways, we’d like to suggest a look at the past to consider the future of insurance regulation. We’d like to highlight efforts made in Wisconsin in the revision of the insurance code done in the 1970’s. The code revision included a little noted provision that allows Wisconsin’s Insurance Commissioner to waive the enforcement of any state insurance law with a public hearing, and a finding that waiving the law will not harm consumers, will not hinder competition, nor harm the insurance market.
It is hard to imagine a similar law passing today, but that level of bold action will be necessary to help bring the insurance market into the future. We strongly support a similar comprehensive review of all NAIC model laws to ensure that they are modernized with the same quick, collaborative action used in this model.
In closing, we are a newly founded InsurTech trade group with experience in life, health, and property and casualty insurance as well as experience as regulators, legislators, strategic and political advisors,, and c-suite executives. We believe it remains vitally important for regulators to be able to understand the changing insurance markets before they come to your state. We stand ready to assist, the NAIC, the members of this committee, and all states to navigate the revolutionary changes that will be coming to the insurance market in the same way the financial markets have been revolutionized.
Thank you for the opportunity to provide public comments on this important document. We look forward to working with you. If you have any questions please do not hesitate to contact us at the email addresses below.
Respectfully Submitted,
Scott Harrison (sharrison@americaninsurtech.com)
Jack Friou (jfriou@americaninsurtech.com)
The Hon. Thomas Mays (tmays@americaninsurtech.com)
JP Wieske (jpwieske@americaninsurtech.com)
Teri Hernandez (thernandez@americaninsurtech.com)
* Co-Founders, American InsurTech Council