Chairwoman Ward and Members of the Labor and Commerce Committee: The National Association of Mutual Insurance Companies (NAMIC) appreciates the opportunity to register its opposition to SB 1202. The National Association of Mutual Insurance Companies is the largest property/casualty insurance trade group with a diverse membership of more than 1,400 local, regional, and national member companies, including seven of the top 10 property/casualty insurers in the United States. NAMIC members lead the personal lines sector representing more than 55 percent of the auto market in the Commonwealth. SB 1202, as reported out by the subcommittee, contains an increase to Virginia’s minimum financial responsibility limits to $30,000 per person / $60,000 per accident / $25,000 property. When SB 1202 was heard in subcommittee on Tuesday, the subcommittee removed an automatic escalation clause that would further increase those limits to $50,000 per person / $100,000 per accident / $40,000 property in several years’ time. NAMIC is opposed to the reinsertion of any escalation clause. Automatically increasing the minimum limits – yet again - without data on how the initial increase impacts consumers is an imprudent decision. Please contact me if you have questions or comments about our position. Sincerely, Andrew Kirkner Regional Vice President, Government Affairs Mid-Atlantic and Ohio Valley (540) 440-0360 Akirkner@namic.org

Chairman Heretick and other distinguished subcommittee members, We are asking you to Vote No on SB 1182 - The American Property and Casualty Insurance Association represents nearly 60% of the US property and casualty market and 54.7% of the VA auto market. Passage of SB 1182 raises the auto required liability limits in Virginia which could have serious financial impact for the consumers and businesses . According to the VA Bureau of Insurance based on most current information for 2017 from a market 2019 data call, around 15% of Virginia drivers carry minimum auto limits. Current law requires limits for bodily injury (BI) of one person at $25,000, $50,000 for more than one person and $20,000 for property damage (PD) SB 1182 would DOUBLE required coverage to $50,000/100,000 for BI and DOUBLE the amount for PD to $40,000 which reflects in higher costs. A 2018 stakeholder study by the DMV looked at this issue . See: Virginia Automobile Insurance Study, December 2018 Virginia Department of Motor Vehicles https://www.dmv.virginia.gov/documents/auto_insurance.pdf The Report’s recommendation #2 stated Virginia should maintian current limits 25,000/50,000 bodily injury and $20,000 property damage automobile liability insurance minimum limits. The Study said, in 2016, 90% of the claims for bodily injury were below the current $25,000 limits bodily injury limits and 99% of property damage claims were below $20,000, HAS ANY OF YOUR CONSTITUENTS COMPLAINED THEY CAN'T BUY HIGHER LIMTS? Most states (43) are at $25,000 /50,000 for bodily injury limits or lower. NO STATE IN THE COUNTRY has $40,000 for property damage, the highest amount is $25,000. VIRGINIA WOULD HAVE THE HIGHEST AUTO LIMITS IN THE COUNTRY. Our neighbors such as MD and NC carry $30,000/$60,000 and PA DC WV are lower. WHO IS ASKING FOR THIS BILL? Where is the need? This mandates coverage instead of consumer choice. Voters would be guaranteed a hefty premium increase, and it would fall hardest on those who could least afford it. The 2018 DMV study found that an average male age 45 would see average liability costs increase by 11.68% if increased to 50,000/100,000. A 20-year-old male would see an average increase of 9.46% across the state or an average up to $252.00 per vehicle. Protect your constituents' pocketbooks and vote NO on SB 1182.

SB1182 would result in a significant increase in the cost of automobile liability insurance for consumers who are presently being stretched to the max by other issues beyond their control. There has not been a demonstrated need expressed by the proponents. This bill would make Virginia an outlier when compared to our neighboring states as well as states across the country. Without a demonstrated need there is no reason to cause consumers to spend more of their funds on something that is not needed. Virginia Farm Bureau Mutual Insurance Company respectfully request that you not act favorably on this bill. SB1195 is a bill that would totally re-write Virginia law with respect o Underinsured Motorist coverage. This bill will result in a significant increase in automobile insurance premiums. This is a bill that is not in the best interest of the majority of Virginia's citizens as consumers. Virginia Farm Bureau Mutual Insurance Company requests that you not act favorably on this bill. l

SB1202 is a proposal that is not based upon any showing of a demonstrated need. the number of complaints received by the Bureau as compared to the number of claims made against this coverage is very insignificant. The bill creates an ambiguous standard upon which bad faith would be viewed by using the phrase failure to accept a reasonable demand. The damages which could be awarded are disproportionate to the harm which could be alleged.

Vote No on SB 1182 - The American Property and Casualty Insurance Association represents nearly 60% of the US property and casualty market and 54.7% of the VA auto market. Passage of SB 1182 raises the auto required minimum liability limits in Virginia which could have serious financial consequences for the consumers and businesses alike. According to the VA Bureau of Insurance based on most current information for 2017 from a market 2019 data call, around 15% of Virginia drivers carry minimum auto limits. Current law requires limits for bodily injury (BI) of one person at $25,000, $50,000 for more than one person and $20,000 for property damage (PD) SB 1182 would DOUBLE required coverage to $50,000/100,000 for BI and DOUBLE the amount for PD to $40,000 which reflects in higher costs. A 2018 stakeholder study by the DMV looked at this issue . See: Virginia Automobile Insurance Study, December 2018 Virginia Department of Motor Vehicles https://www.dmv.virginia.gov/documents/auto_insurance.pdf See: The Report’s recommendation #2 stated Virginia should maintian current limits 25,000/50,000 bodily injury and $20,000 property damage automobile liability insurance minimum limits. The Study said, in 2016, 90% of the claims for bodily injury were below the current $25,000 limits bodily injury limits and 99% of property damage claims were below $20,000, HAS ANY OF YOUR CONSTITUENTS COMPLAINED THEY CAN'T BUY HIGHER LIMTS? Most states (43) are at $25,000 /50,000 for bodily injury limits or lower. NO STATE IN THE COUNTRY has $40,000 for property damage, the highest amount is $25,000. VIRGINIA WOULD HAVE THE HIGHEST AUTO LIMITS IN THE COUNTRY. Our neighbors such as MD and NC carry $30,000/$60,000 and PA DC WV are lower. WHO IS ASKING FOR THIS BILL? Where is the need? This mandates coverage instead of consumer choice. Voters would be guaranteed a hefty premium increase, and it would fall hardest on those who could least afford it. The 2018 DMV study found that an average male age 45 would see average liability costs increase by 11.68% if increased to 50,000/100,000. A 20-year-old male would see an average increase of 9.46% across the state or an average up to $252.00. Protect your constituents' pocketbooks and vote NO on SB 1182.

Chairman Heretick and other distinguished subcommittee members, The American Property Casualty Insurance Association (APCIA) is a national trade organization representing nearly 60 percent of the U.S. property casualty insurance market and members write 54.7% of the total VA auto market for personal and commercial vehicles. Thank you for the opportunity to provide comments in opposition to SB 1195, a bill that changes the definition of underinsured motorists (UIM) for auto insurance for both consumers and businesses. This is a very complex issue but the current offset UIM definition would change VA's law which is the majority of the states to an excess definition. WHY IS IT NEEDED? Consumers can already buy higher limits. This is a complex issue, why is the being rushed through the legislature? This change should be studied to determine the financial impact on auto insurance. States with definitions similar to those outlined in SB 1195 have costs that are 86% higher than Virginia’s under current law. These costs likely will be passed down to consumers in the form of higher auto insurance rates. APCIA’s analysis, using data for uninsured/underinsured motorist coverage for bodily injury (UM/UIM-BI), found that the average loss per insured car in states with an excess UIM provision is more than twice as much as the average loss per insured car in states with an offset UIM provision. APCIA estimates that if a state had converted its offset trigger to an excess trigger five years ago, policyholders’ UM/UIM-BI premium could have potentially increased 108.1 % (i.e., more than doubled). Higher insured costs are found in excess states than in states with offset trigger provisions. While states with a excess trigger provide more coverage, it also costs more than twice as much for insurers and their customers. Offset triggers and offsets for the at-fault driver’s liability limit benefit all policyholders and, as such, should continue to be allowed During this time of continued economic recovery, keeping costs down for consumers and businesses should be the most significant consideration. APCIA respectfully urges lawmakers to defeat SB 1195 Vote NO on SB 1195. It needs further review. Also consider, based on APCIA cost estimates of SB 1195 along with the impact of SB 1202, the two uninsured motorists vehicle bills could add an ESTIMATED INCREASE in cost of $152 PER VEHICLE. Consumers and Businesses do not need more pressure on their budgets and are not requesting these laws, APCIA respectivefullully requests SB 1195 be defeated.

SB1182 would result in a significant increase in the cost of automobile liability insurance for consumers who are presently being stretched to the max by other issues beyond their control. There has not been a demonstrated need expressed by the proponents. This bill would make Virginia an outlier when compared to our neighboring states as well as states across the country. Without a demonstrated need there is no reason to cause consumers to spend more of their funds on something that is not needed. Virginia Farm Bureau Mutual Insurance Company respectfully request that you not act favorably on this bill. SB1195 is a bill that would totally re-write Virginia law with respect o Underinsured Motorist coverage. This bill will result in a significant increase in automobile insurance premiums. This is a bill that is not in the best interest of the majority of Virginia's citizens as consumers. Virginia Farm Bureau Mutual Insurance Company requests that you not act favorably on this bill. l

Chairman Heretick and other distingushed sub committee members, The American Property Casualty Insurance Association (APCIA) is a national trade organization representing nearly 60 percent of the U.S. property casualty insurance market and members write 54.7% of the total VA auto market for personal and commercial vehicles. Thank you for the opportunity to provide comments in opposition to SB 1195, a bill that changes the definition of underinsured motorists (UIM) for auto insurance for both consumers and businesses. This is a very complex issue but the current offset UIM definition would change VA's law which is the majority of the states to an excess definition. WHY IS IT NEEDED? Consumers can already buy higher limits. This is a complex issue, why is the being rushed through the legislature? This change should be studied to determine the financial impact on auto insurance. States with definitions similar to those outlined in SB 1195 have costs that are 86% higher than Virginia’s under current law. These costs likely will be passed down to consumers in the form of higher auto insurance rates. APCIA’s analysis, using data for uninsured/underinsured motorist coverage for bodily injury (UM/UIM-BI), found that the average loss per insured car in states with an excess UIM provision is more than twice as much as the average loss per insured car in states with an offset UIM provision. APCIA estimates that if a state had converted its offset trigger to an excess trigger five years ago, policyholders’ UM/UIM-BI premium could have potentially increased 108.1 % (i.e., more than doubled). Higher insured costs are found in excess states than in states with offset trigger provisions. While states with a excess trigger provide more coverage, it also costs more than twice as much for insurers and their customers. Offset triggers and offsets for the at-fault driver’s liability limit benefit all policyholders and, as such, should continue to be allowed During this time of continued economic recovery, keeping costs down for consumers and businesses should be the most significant consideration. APCIA respectfully urges lawmakers to defeat SB 1195 Vote NO on SB 1195. It needs further review. Also consider, based on APCIA cost estimates of SB 1195 along with the impact of SB 1202, the two uninsured motorists vehicle bills could add an ESTIMATED INCREASE in cost of $152 PER VEHICLE. Consumers and Businesses do not need more pressure on their budgets and are not requesting these laws, APCIA respectivefully requests this bill be defeated.

On behalf of State Farm Insurance Companies, I endorse and echo the comments in opposition to SB1202 made by speakers commenting on behalf of APCIA, NAMIC and USAA. Thank you for your attention. Respectfully, Cynthia Hudson (Sands Anderson PC)

Chair Heretick and other distinguished delegates, Vote No on SB 1202. The American Property and Casualty Insurance Association represents nearly 60% of the US property and casualty market and 54.7% of the VA auto market. This bill is not needed and comes at a time when consumers and local businesses are struggling. A recent Milliman study for similar bill in Florida showed that this type of action would increase loss costs by 22% per vehicle. The bill provides if bad faith is found that an insurance company is subject to unlimited exposure but there has been no indication that cos are not acting in good faith. Where is the need? The VA bureau of Insurance indicated that over a 3 year period from 2017-2020 there were 38 complaints regarding uninsured motorists and not one company was found to have acted in bad faith. Combine this bill with SB 1195 and consumers and businesses will see an increase of estimated $152 PER VEHICLE. Please vote No on SB 1202. .

SB1202 is a proposal that is not based upon any showing of a demonstrated need. the number of complaints received by the Bureau as compared to the number of claims made against this coverage is very insignificant. The bill creates an ambiguous standard upon which bad faith would be viewed by using the phrase failure to accept a reasonable demand. The damages which could be awarded are disproportionate to the harm which could be alleged.

SB1202 is a proposal that is not based upon any showing of a demonstrated need. the number of complaints received by the Bureau as compared to the number of claims made against this coverage is very insignificant. The bill creates an ambiguous standard upon which bad faith would be viewed by using the phrase failure to accept a reasonable demand. The damages which could be awarded are disproportionate to the harm which could be alleged.

The National Multiple Sclerosis Society writes to express serious concern regarding SB 1341, to expand association health plans in the Commonwealth. While the Society acknowledges the need for more affordable health insurance coverage, AHPs are not a viable solution and do not meet the needs of people living with high-cost, complex, chronic conditions like multiple sclerosis. Association health plans skirt important ACA patient protections and can discriminate against Virginians living with MS. Further, as written in this bill (lines 186-188) these plans are not insurance - yet provisions in the bill point to Title 38, Virginia’s insurance code. There is no clear legal authority for the Bureau of Insurance to regulate these plans, as noted in the BOI’s own impact statement on the bill. The law, as written, cannot be implemented. Association health plans do not meet the needs of people living with MS, and pose serious risks to the overall stability of the ACA Marketplace. Instead of expanding association health plans in the Commonwealth, let’s help ALL Virginians by implementing a state reinsurance program instead. The Society strongly urges you to vote no on SB 1341.

Dear Members of the Committee & Committee Chair: Please OPPOSE SB 1341 - based on expertise provided by prominent organization The Commonwealth Fund, as follows: "The Trump administration had made the formation of association health plans (AHPs) — those offered by business or professional associations to their members — a central focus of its health policy agenda by significantly expanding their reach, but a federal court decision made in March has found the new rules violate federal tax law. AHPs have existed for decades. Many are legitimate arrangements made by associations to offer health benefits to members, but some have defrauded enrollees or ended up insolvent, unable to pay members’ claims. AHPs can set rates for their small-group members based on the health status of the small group. This cherry-picking of good risks will make coverage less expensive for people with lower health care costs, but it is likely to raise premiums for those with preexisting conditions who remain in the ACA-compliant market. The AHP rule is based on a different vision of health insurance markets than the philosophy of the ACA — a vision that values lower cost for some over coverage for all."

Thank you for the opportunity to provide comments on behalf of the American Lung Association in Virginia and the patients we serve with lung disease and on behalf of all the Virginians who depend on access to adequate, affordable and accessible health coverage. Lung Disease patients including those with asthma, lung cancer, and acute bronchitis have unique health needs. Comprehensive coverage is vital to ensure all lung disease patients have access to the medications, treatments and specialists they require to live. The American Lung Association strongly opposes SB 1341 that would allow any expansion of Association Health Plans. SB 1341 creates plans that are defined as not insurance coverage • As drafted the plans created are not required to comply with current state regulation and the patient protects of the Affordable Care Act (lines 183-184 demonstrate this) • While they may appear to provide protections for people with pre-existing conditions, the referenced code is only applicable to insurance policies. SB 1341 puts people who purchased plans on the individual market at risk • These plans could market to and attract younger, healthier individuals, pulling them out of the marketplace, leading to potential higher premiums for those that remain, essentially cherry-picking healthier consumers and allowing sicker patients to remain in the marketplace • This bill would allow AHPs to charge older adults 5 times as much for their premiums, which is much more limited in ACA complaint plans SB 1341 would be available to groups beyond Realtors in Virginia • These plans could be sold in other states, as long as just one member lives in Virginia • There is nothing prohibiting another group to seek the same authorization and create their own plan, therefore potentially destabilizing the ACA marketplace Association Health Plans (AHPs) are the wrong solution. These plans pose risks to patients and consumers and the Lung Association is asking that you PLEASE VOTE NO on SB 1341. The American Lung Association thanks you for the opportunity to share our comments on this proposed piece of legislation. We hope that you will act to protect patients with lung disease and all those who rely on adequate, affordable and accessible health care.

Dear Chairman Heretick and other members of the Committee: I am writing to you to urge you to oppose SB 1341, which would have negative impacts on the marketplace—and consequently on small businesses that already struggle with healthcare costs. Ensuring strong and robust individual and small group healthcare marketplaces is vitally important to Virginia’s entrepreneurs because this is essential to keeping costs down for business owners and their employees. Unfortunately, SB 1341 would create a less protected insurance market that would only drive up premiums. For instance, as drafted, SB 1341 is not defined as insurance coverage, meaning it does not have to comply with state requirements or patient protection under the Affordable Care Act (ACA). In fact, the legislation’s premium allowable rating is a 5:1 ratio, meaning an insurer could charge older adults up to five times the normal premium amount. This does not comply with the Affordable Care Act’s guidelines of a 3:1 ratio. What’s more, this bill would not be limited to realtors in Virginia. The bill would allow these plans to be sold in other states, so long as one member lives in Virginia, further incenting other groups to recreate this model, resulting in a destabilized ACA marketplace. These plans put small businesses at risk since they are not treated like traditional insurance, which limits the state’s ability to protect those with pre-existing conditions. Though these plans might make it easier for younger and/or healthier employees to purchase coverage through association health plans, the tradeoff is small employers with older and/or sicker workers would end up paying more. Furthermore, consumers who would need robust healthcare would eventually be priced out as well. Association health plans are dangerous additions to the marketplace that undermine the small group market and could raise costs for small business owners. I strongly urge you to oppose SB 1341.