On July 2, 2025, the Connecticut Insurance Department (Department) issued Bulletin PC-92-25 (Bulletin), addressed to “all companies licensed to write property and casualty insurance.” The Bulletin rescinds and replaces Bulletin PC-92, dated July 23, 2021, concerning flex-rate filings and provides additional guidance to insurers for rate filings submitted on and after June 30, 2025. The Bulletin provides that Public Act No. 25-86 extended the flex-rating provisions under Conn. Gen. Stat. § 38a-688a until July 1, 2030.
Pursuant to Conn. Gen. Stat. § 38a-688a, as amended, a rate filing by an insurer,[1] on and after July 1, 2006, and until July 1, 2030, with respect to voluntary market personal risk insurance, is effective the date such rate filing is made with the Department “provided the rate provides for an overall state-wide rate increase or decrease of not more than six per cent [6%] in the aggregate and not more than a fifteen per cent [15%] increase in any individual territory for all coverages that are subject to the filing.” Conn. Gen. Stat. § 38a-688a(a). Moreover, an insurer may only file a flex-rate filing within any 12-month period. The foregoing statute also clarifies that the percentage limits do not apply on an individual insured basis. The Bulletin states that the Department “does not consider changes to an insurer’s rating plan…to fall under the Flex-Rate Filing provisions…unless the insurer is adopting a rating plan, including all supplemental rate information, that is currently approved for use by other licensed insurers and/or advisory/rating organizations.” The Department also does not “consider changes involving a significant number of relativity factor tables and/or use of a Generalized Linear Model or other new unique modeling methodology to fall under the Flex-Rate Filing provisions.” Finally, unless otherwise exempt, filings that do not meet the criteria under Connecticut’s flex-rate filing provisions are still subject to §§ 38a-389 and 38a-688 relating to rate filings.
Insurers that submit a flex-rate filing must identify in the transmittal letter as well as under the SERFF “filing type” that the filing is being submitted under the flex-rate filing provisions and must include a statement that the filing complies with the requirements as set forth under Conn. Gen. Stat. § 38a-688a. Such filing shall also clearly identify the proposed effective date(s) for new and renewal business subject to the filing. Moreover, insurers submitting a flex-rate filing must provide a separate exhibit that indicates “the overall aggregate rate impact by territory and towns in the territory.” Finally, the Bulletin contains various frequently asked questions in connection with the flex-rate filing provisions of § 38a-688a.
[1] The Bulletin notes that for “purposes of determining compliance with the Flex-Rate Filing provisions [of § 38a-688a], no individual insurer within a group of insurers may exceed the 6% rate increase or decrease and not more than a 15% increase in any individual territory within a twelve month period. A filer cannot average the total increases and/or decreases of an insurer’s individual rate increases that are a part of a group filing for purposes of determining whether the flex filing thresholds have been exceeded.”
