BILL ANALYSIS                                                                                                                                                                                                    



                                                                       



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          |SENATE RULES COMMITTEE            |                  AB 2002|
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                                    CONSENT


          Bill No:  AB 2002
          Author:   Huffman (D)
          Amended:  As introduced
          Vote:     21

           
           SENATE BANKING, FINANCE, AND INS. COMMITTEE  :  9-0, 6/16/10
          AYES:  Calderon, Cogdill, Florez, Kehoe, Liu, Lowenthal,  
            Padilla, Price, Runner
          NO VOTE RECORDED:  Correa, Cox
           
          ASSEMBLY FLOOR  :  70-0, 4/15/10 (Consent) - See last page  
            for vote


           SUBJECT  :    Reserve requirements

           SOURCE  :     Firemans Fund Insurance Company 


           DIGEST  :    This bill provides for across-the-board  
          application of risk-based capital financial oversight to  
          insurers operating in California by repealing a  
          pre-risk-based capital statute that mandates a statutory  
          minimum level of capital reserving for certain non-auto and  
          automobile bodily injury liability insurers as an exception  
          to the reserving practices and law which would otherwise  
          apply. 

           ANALYSIS  :    

          Existing law:

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          1. Provides that reserves for each of the three previous  
             years for lines of insurance described on insurers'  
             annual statements as "liability other than automobile  
             bodily injury" and "automobile bodily injury" be not  
             less than 60 percent of the earned premiums for each of  
             those three years, and that the Insurance Commissioner's  
             regulations reflect this rule for these lines of  
             insurance.

          2. Grants the Insurance Commissioner a broad range of  
             powers to regulate the solvency of insurance companies  
             doing business in California, including the right to  
             examine any insurer's books and records, to evaluate the  
             quality of its investments, to evaluate the type of  
             insurance risk it has assumed, and to evaluate the  
             reinsurance it has purchased, among other tools.

          3. Establishes a financial analysis tool formulated under  
             the guidance of the National Association of Insurance  
             Commissioners (NAIC) called "risk-based capital" (RBC)  
             which involves an analysis of each insurer's risk  
             profile, including its underwriting risks, its  
             investment risks, its credit risks, and other factors  
             designed to evaluate the ability of the insurer to meet  
             its obligations.  Depending on an insurer's RBC "score,"  
             an escalating level of regulatory intervention is  
             authorized.

          4. Requires insurers generally to comply with the  
             Accounting Practices and Procedures Manual (APPM)  
             adopted by NAIC, unless a specific statute overrides  
             this rule.  The 60 percent reserve rule, which predates  
             both the RBC law and the NAIC APPM law, operates in  
             California as an exception to this requirement.

          This bill repeals a 41-year-old pre-RBC statute specifying  
          a mandatory fixed reserve level for seven lines of  
          liability insurance in favor of adherence to the NAIC's  
          current RBC approach to solvency monitoring and regulation.

           Background  

          The NAIC established the RBC framework to provide a  
          methodology by which insurance regulators could identify  







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          weakly capitalized companies.  The RBC system is a  
          regulatory tool which permits regulatory action based on  
          RBC ratios, which are not designed to compare capital  
          strength of companies.  In general, RBC-based minimum  
          capital requirements are expected to be sufficient to  
          protect insurer solvency 95 percent of the time.  
           
           Prior Legislation
           
          SB 316 (Yee), Chapter 431, Statutes 2007, repealed a  
          similar "65% reserve rule" applicable to workers'  
          compensation insurers.  The bill was passed unanimously by  
          both the Assembly and Senate.

           FISCAL EFFECT  :    Appropriation:  No   Fiscal Com.:  No    
          Local:  No

           SUPPORT  :   (Verified  6/17/10)

          Fireman's Fund Insurance Company (source)


           ARGUMENTS IN SUPPORT  :    The bill's sponsor, the Fireman's  
          Fund Insurance Company, notes it has made its home in  
          California for 147 years and is the state's second largest  
          domestic insurer with nearly 2,000 employees in the state.   
          The Fireman's Fund states:

            "Section 11558, while useful decades ago, no longer  
            serves its intended purpose; allocation of financial  
            reserves necessary to pay claims for specific lines of  
            liability insurance.  Unlike California, other state  
            insurance regulatory laws do not use minimum reserves of  
            the type found in Section 11558.  Instead, Risk Based  
            Capital (RBC) standards which are far more comprehensive  
            are now used by state regulators and the National  
            Association of Insurance Commissioners to track and  
            ensure that insurers are able to pay their claims.  Use  
            of consistent, national RBC standards allows regulators  
            in all states to apply consistent financial strength  
            tests to insurers. 

            "Not only is Section 11558 inconsistent with the  
            standards used all other states, but it is inconsistent  







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            with the RBC standards applied by the CDI for evaluation  
            of all other insurance lines of business within Fireman's  
            Fund own operations. This puts California domiciled  
            insurers at a disadvantage relative to insurers from  
            outside of the state to whom Section 11558 does not  
            apply.   

            "The changes proposed by AB 2002 will foster consistency  
            in financial oversight for California based insurers,  
            while not impacting the financial oversight provided  
            under California's RBC rules."


           ASSEMBLY FLOOR  :
          AYES:  Ammiano, Anderson, Arambula, Bass, Beall, Bill  
            Berryhill, Tom Berryhill, Blakeslee, Blumenfield,  
            Bradford, Brownley, Buchanan, Caballero, Charles  
            Calderon, Carter, Chesbro, Conway, Cook, Coto, Davis, De  
            La Torre, De Leon, Emmerson, Eng, Feuer, Fletcher, Fong,  
            Fuentes, Fuller, Furutani, Gaines, Galgiani, Garrick,  
            Gilmore, Hagman, Hall, Harkey, Hayashi, Hernandez, Hill,  
            Huber, Huffman, Jeffries, Knight, Lieu, Logue, Bonnie  
            Lowenthal, Ma, Mendoza, Miller, Monning, Nava, Nestande,  
            Niello, Nielsen, V. Manuel Perez, Portantino, Salas,  
            Saldana, Silva, Skinner, Smyth, Solorio, Audra  
            Strickland, Swanson, Torlakson, Torres, Villines, Yamada,  
            John A. Perez
          NO VOTE RECORDED:  Adams, Block, DeVore, Evans, Jones,  
            Norby, Ruskin, Torrico, Tran, Vacancy


          JJA:mw  6/17/10   Senate Floor Analyses 

                         SUPPORT/OPPOSITION:  SEE ABOVE

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