Public Comments for 02/18/2021 Labor and Commerce
SB1182 - Motor vehicle liability insurance; increases coverage amounts.
Last Name: Kirkner Organization: National Association of Mutual Insurance Companies Locality: Henrico

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

Last Name: Egan Organization: American Property & Casualty Insurance Association Locality: Chicago

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.

Last Name: Logan Organization: Virginia Farm Bureau Mutual Insurance Company1 Locality: Midlothian,

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

Last Name: Logan Organization: Virginia Farm Bureau Mutual Insurance Company1 Locality: Midlothian,

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.

Last Name: Egan Organization: American Property & Casualty Insurance Association Locality: Baltimore

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.

Last Name: Kowar Organization: Professional Insurance Agents Association of Virginia and DC Locality: Hanover

We are asking you to amend SB 1182 which increases the required liability limits for auto insurance. Under current law if you can't afford or don't desire to purchase automobile liability insurance, you can pay the DMV an uninsured motorist fee. If this bill gets passed, many more Virginia drivers will become uninsured instead of buying the higher more expensive limits. Therefore, we ask that you amend this bill to increase the uninsured motorist fee to the DMV to $750 payable to the Uninsured Motorist Fund which is used to reduce the cost of uninsured motorist insurance coverage. Please pass with the amendment.

SB1195 - Motor vehicle insurance; underinsured motor vehicle, uninsured motorist coverage.
Last Name: Egan Organization: American Property & Casualty Insurance Association Locality: Chicago

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.

Last Name: Logan Organization: Virginia Farm Bureau Mutual Insurance Company1 Locality: Midlothian,

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

Last Name: Egan Organization: American Property & Casualty Insurance Association Locality: Baltimore

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.

Last Name: Kowar Organization: Professional Insurance Agents Association of Virginia and DC Locality: Hanover

We are opposed to SB 1195. 1. Passage of SB 1195 would completely rewrite our state’s definition of “underinsured” when determining uninsured motorist (UIM) coverage, moving Virginia from a state that uses an “offset” provision to one that uses an “excess” provision in order to determine when UIM coverage is necessary. This change could significantly increase the number of claims that qualify for UIM coverage, thus increasing loss costs thus putting significant upward pressure on auto insurance rates for Virginia consumers. 2. In fact, states with definitions of underinsured and uninsured motorist bodily injury 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. 3. Why Now? There is never a good time to raise insurance rates for hardworking Virginians, but now is an especially bad time to do so. Please help keep insurance costs down across the state by opposing SB 1195. Virginia has the 17th lowest rate of uninsured motorists in the country, but this bill is very likely to increase that trend. Voters would be extremely likely to face a hefty premium increase, and it would fall hardest on those who could least afford it.

SB1219 - Paid family and medical leave; SCC's Bureau of Insurance to review and make recommendations, report.
Last Name: deButts Organization: Loudoun County Chamber of Commerce Locality: Loudoun County

The Loudoun Chamber, which collectively represents over 1,000 member businesses and tens of thousands of employees across Loudoun County and the region, would like to express our organization’s support of Senator Favola’s SB 1219. This bill will require the Bureau of Insurance (BOI) to convene a stakeholder group and make recommendations on how to incentivize employers to voluntarily offer 12- weeks of family leave to employees per year. The Loudoun Chamber is adamant that any wage and benefits expansion in the Commonwealth must be considered along with the thoughtful collaboration of the business community and employees who will be responsible for the financial commitment of the benefit. Senator Favola’s Bill, not only accomplishes this goal in the formation of a stakeholder group, but does so with the explicit outcome to recommend a voluntary, incentive-focused, solution that will enable the benefit to be administered through the private insurance marketplace. Currently, the BOI does not have the statutory authority to approve the sale of family leave plans in the Commonwealth. Private insurance options are an essential tool for employers looking to provide paid leave coverage and Virginia employers currently do not have access to private leave plans. Filling this gap in our insurance marketplace is the necessary and pragmatic first step in the long-term goal of having more employees covered by family leave plans in the Commonwealth. Thank you for your consideration of support for SB1219. Grafton deButts Vice President of Membership & Government Affairs Loudoun Chamber

End of Comments