Last Friday the Ohio Department of Insurance issued Bulletin 2009-11 mandating that by Dec. 31, 2009, all insurance entities doing business in Ohio will be required to electronically submit rate, rule and form filings for all lines of insurance using the System for Electronic Rate and Form Filing.
According to the bulletin and ODI press release, SERFF is made available to states via the National Association of Insurance Commissioners and is viewed by regulators as a “speed to market” tool. Filing entities may sign up for SERFF by contacting the SERFF Marketing Team at 816-783-8787 or via email at firstname.lastname@example.org. After Dec. 31, 2009, the Office of Product Regulation and Actuarial Services will no longer accept paper filing submissions.
The bulletin includes a “hardship” provision for companies that do not believe they can comply with the mandate. Any insurance entity that will not be able to file all submissions via SERFF by Dec. 31 must provide an email notice to ODI no later than Nov. 1, 2009, articulating the reasons why compliance with the requirement constitutes a hardship. Notices of hardship or questions regarding property/casualty or title insurance filing submissions should be sent to email@example.com.
Although the mandatory deadline is Dec. 31, 2009, those entities not already filing via SERFF are encouraged to immediately begin making arrangements to do so. Entities that utilize authorized filers to make filings on their behalf are encouraged to immediately notify their authorized filers to make arrangements to be SERFF compliant before the deadline. Entities also are encouraged to take formal training so that they can fully utilize the SERFF system. Contact information regarding training can be found on the SERFF website. More information about SERFF, including the data hosting solutions, is available on the SERFF website at https://www.serff.com.
With adoption of this bulletin, Ohio becomes the 23rd state to mandate SERFF filings. NAMIC's compliance chart provides national perspective on this issue.
Direct questions to NAMIC's Assistant Vice President of State Affairs Joe Thesing.