Meeting Packet — Insurance & Banking Subcommittee, The Florida House of Representatives (January 13, 2021)
Summary
Meeting packet for the Insurance & Banking Subcommittee of the Commerce Committee of The Florida House of Representatives, Wednesday, January 13, 2021, 4:00 PM – 5:00 PM, Morris Hall (12 HOB). The agenda lists a Citizens Property Insurance item on its impact on the Florida Property Insurance Market, with topics Availability vs Affordability and Criteria for Citizens Initial and Continuing Eligibility. The packet includes a presentation by Barry Gilway, President/CEO and Executive Director of Citizens Property Insurance Corporation, stating that Citizens was created in 2002. The slides list a Citizens Policyholder Surcharge of up to 15%, a Regular Assessment of up to 2% and an Emergency Assessment of up to 10% per year, and state that no assessments are currently being levied.
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“Meeting Packet — Insurance & Banking Subcommittee, The Florida House of Representatives (January 13, 2021).”
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Insurance & Banking Subcommittee
Wednesday, January 13, 2021
4:00 PM – 5:00 PM
Morris Hall (12 HOB)
Meeting Packet
Chris Sprowls Nick DiCeglie
Speaker Chair
The Florida House of Representatives
Commerce Committee
Insurance & Banking Subcommittee
Chris Sprowls Nick DiCeglie
Speaker Chair
Meeting Agenda
Wednesday, January 13, 2021
4:00 PM – 5:00 PM
Morris Hall (12 HOB)
I. Call to Order
II. Roll Call
III. Welcome and Opening Remarks
IV. Citizens Property Insurance and Its Impact on the Florida Property Insurance Market:
• Availability vs Affordability
• Criteria for Citizens Initial and Continuing Eligibility
• Citizens Rate Filing Compared to a Private Market Insurer
V. Closing Remarks
VI. Adjournment
303 House Office Building, 402 South Monroe Street, Tallahassee, FL 32399-1300
(850) 717-4870
Citizens Property Insurance
Citizens Property Insurance Corporation
Barry Gilway, President/CEO and Executive Director
House Insurance and Banking Subcommittee
January 13, 2021
~ ITIZ"~~
PftOPERTY INSURAN
Overview
• In 2002, Citizens was created as a not-for-profit, tax-exempt government entity whose public
purpose is to provide property insurance coverage to those unable to find coverage in the
voluntary admitted market or if coverage in the voluntary admitted market is more than 15%
higher than coverage with
• Created from the merger of the Florida Windstorm Underwriting Association (FWUA) and the
Florida Residential Property and Casualty Joint Underwriting Association (FRPCJUA)
o FWUA: created in 1972 as insurer of last resort to provide wind-only coverage in Monroe
County. The wind-only territories of the FWUA were expanded over time to include most
coastal regions
o FRPCJUA: created in 1992 following Hurricane Andrew as an insurer of last resort for areas
of the state not covered by the FWUA
• Governed by a nine-member board of Governors, three of whom are appointed by the Governor
and two of whom are each appointed by the Chief Financial Officer, Senate President and
Speaker of the House
• Operate pursuant to a plan of operation which is reviewed and approved by the Financial
Services Commission
• Subject to regulation by the Florida Office of Insurance Regulation (OIR), Operational Reviews by
the Auditor General and OIR Market Conduct Examiners, and external audits
• Citizens also has a robust Office of Internal Audit and an Inspector General
Page 2 ~ ITIZ.~t!~
PROPERTY INSURAN
Overview
• When Citizens was created, each of the predecessor organizations had slightly different coverage
offerings and outstanding indebtedness, requiring the premium associated with each to remain
aligned.
• Each of the following three accounts are separate statutory accounts and have separate
calculations of surplus, plan-year deficit and assessment bases. Assets in one account many not be
comingled or used to fund losses in another account. The three accounts are listed below with the
types of policies written in each.
o Personal Lines Account (PLA)
Personal Residential Multiperil policies, including homeowners, dwelling fire, mobile home,
tenants and condominium unit owners, These policies tend to be located further inland or
in non-coastal areas of the state
o Coastal Account (Formerly High Risk Account)
Wind-only and multiperil policies for personal residential, commercial residential and
commercial nonresidential risks located in eligible coastal high risk areas
o Commercial Lines Account (CLA)
Commercial Residential Multiperil policies, including condominium associations, apartment
buildings and homeowners association policies
Commercial Nonresidential Multiperil policies located outside of the coastal (HRA) eligible
areas
Page 3 ~ ITIZ.~t!~
PROPERTY INSURAN
Eligibility
• Under Florida law, Citizens may write a new insurance policy only for property that
meets one of the following eligibility criteria:
• Coverage is not available from a Florida-authorized insurance company
• Premiums for coverage from Florida-authorized insurance companies are more
than 15 percent higher than the premiums for comparable coverage from
Citizens
• In 2013, the legislature created a Property Insurance Clearinghouse to help identify
private-market insurance options for consumers who believe Citizens might be their
only choice for property insurance and to ensure that only customers who are eligible
obtain coverage from Citizens
• Citizens' Depopulation Program, authorized by Florida law, matches Citizens
policyholders with insurance companies interested in removing their policies from
Citizens and providing private-market coverage for their policies. All companies
assuming policies from Citizens have been approved by the OIR
Page 4 ~ ITIZ.~t!~
PROPERTY INSURAN
Financial Resources
• Citizens has at its disposal both the traditional resources available to all property and
casualty companies that conduct business in the state as well as assessment powers
granted to Citizens by law.
Traditional Financial Resources Unique Financial Resources
• Insurance Premiums • Citizens’ Policyholder Surcharges (All Citizens
• Investment Income policyholders)
• Operating Surplus from Prior Years • Regular Assessments (Coastal only)
• Florida Hurricane Catastrophe Fund Reimbursements • Emergency Assessments
• Traditional Reinsurance and Capital Markets Risk • Pre-event liquidity resources (debt issuances and lines of
Transfer credit which, if drawn upon, must be repaid)
Page 5
Assessments
Citizens Policyholder Surcharge
Up to 15% per account for Coast al Account, PLA, and/or CLA deficits
Appl ies at new business/renewal for all Citizens' policyholders
Regular Assessment
Up to 2% for Coastal Account deficits
Appl ies at new business/renewal for all non-Citizens' policyholders
3.
Emergency Assessment
Up t o 10% per yea r per accou nt for Coast al Account, PLA and/or CLA deficits
Applies at new business/renewa l for all Citizens' and no n-Citizens' policyholders
Page 6
~ ITIZENS
PROPERTY INSURANCE CORPORATION
Assessments
• The 2005 Emergency
Assessment was
terminated for policies
issued or renewed
beginning on July 1,
2015
• Currently, no
assessments are being
levied by Citizens
Page 7
Financial Overview
YTD Change Change
Financial Summary (in billions) Q3-2020 2019 2018 Book of Business Nov-2020 Last Mth Last Yr
Surplus 1
$6.4 $6.3 $6.2 Total Premium Inforce $1.169B 3.2% 33.8%
100-YR PML2 $5.3 $4.6 $4.7 Average Premium - PLA $1,953 1.2% 14.1%
Claims-Paying Capacity 3
$10.3 $11.0 $11.5 Average Premium - Coastal $2,825 0.7% 10.1%
Total Cash and Invested Assets $8.8 $8.9 $9.3 Average Premium - CLA $18,361 0.3% 12.5%
1 Accumulated Surplus is determined in accordance with Statutory Accounting Principles (SAP).
2 As of Q4-2014, Single-event occurrence Probable Maximum Loss ("PML“) includes demand surge, excludes storm surge, and does not include LAE.
3 Claims Paying Capacity consists of (1) 2020 Q3 Statutory Surplus, (2) risk transfer for 2020-21 hurricane season (including FHCF coverage), and (3)par
value of pre-event bonds. Please note that this figure shows resources on a combined basis. However, resources are specific to each account and may
not be used to fund needs in another account
• While Citizens continues to retain a strong financial position, the PLA sustained net losses each year from 2015 –
2019. The PLA is projected to have net income of $3.1 million in 2020 and a net loss of $43.2 million in 2021.
Through September 2020, the PLA had (unaudited) net income of $18.3 million, however, contributing to this
was net investment income of $40.8 million. PLA net income (loss) in prior years are as follows:
• Sept 2020 (unaudited): $ 18,322,000
• 2019 (audited): ($ 6,861,000)
• 2018 (audited): ($135,862,000)*
• 2017 (audited): ($555,475,000)*
• 2016 (audited): ($ 35,017,000)
• 2015 (audited): ($ 21,489,000)
*Primarily driven by hurricane losses (Irma and Michael)
Risk and Assessment Reductions
Notes:
1. Storm Risk is as measured by 1-in-100 year probable maximum loss (PML) plus estimated loss adjustment expenses using the Florida Hurricane VALUES ARE NOT DRAWN TO
Catastrophe Fund (FHCF) account allocation where PLA and CLA are combined. PLA/CLA combined PMLs are added to the Coastal PMLs to be SCALE
consistent for surplus distribution. In general, the PMLs presented are as projected at the beginning of storm season; with the exception of 2017 which is
as of August 31, 2017.
2. Surplus and Assessments are as projected at beginning of storm season. Not all PLA/CLA surplus is needed to fund storm risk in 2014. In 2015 - 2020,
not all surplus in PLA/CLA and the Coastal Account is needed to fund storm risk. Remaining surplus is available to fund a second event.
3. Florida Hurricane Catastrophe Fund (FHCF) is as projected at beginning of storm season; with the exception of 2017 and 2018 which are Citizens' initial
data submission to the FHCF.
4. Depopulation PMLs are not included in storm risk totals and are presented as year end totals. PMLs from 2011-2014 use a weighted average of 1/3
Standard Sea Surface Temperature (SSST) and 2/3 Warm Sea Surface Temperature (WSST). 2015 - 2019 PMLs reflect only SSST event catalog. 2020
Depopulation PMLs are not yet available for inclusion in this exhibit.
History of Policies In-Force
1,200,000
Liquidation of 3 FL domestic
carriers and partial withdrawal
Liquidation of Poe from large carrier High volume of
Personal Lines Account
Financial Group depopulr on a ctivity
1,000,000
Coastal Account
\
D 800,000
C:
:,
0
• Commercial Lines Account
I High volume of
de populafon activity
u
High volume of
.~ 600,000 depopulation activity
0
Q. I
400,000 ,..
200,000
1996 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 Nov 2020
P eBonal Lines Commercial PeBonal Lines Commercial
Coastal Account Total Coastal Account Total
Account Lines Account Account Lines Account
1996 936,837 465,739 0 1,402,576 2011 1,003,856 460,161 8,374 1,472,391
2001 102,792 414,123 198 517,113 2012 860,502 446,163 8,146 1,314,811
2002 164,274 397,676 2,157 564,107 201 3 627,391 386,688 7,615 1,021,694
2003 383,283 433,077 3,863 820,223 2014 ,- 373,6 17 282,863 4,681 661,161
2004 416,521 453,765 3,650 873,936 2015 ,~ 299,902 200,842 3,121 503,865
2005 407,387 399,417 3,145 809,949 2016 293,118 160,834 1,891 455,843
2006C2J 743,592 403,509 8,347 1,298,428 2017 300,507 138,591 1,308 440,406
2007 845,857 446,184 12,908 1,304,949 2018 304,507 121,971 91 9 427,397
2008 629,467 445,200 9,570 1,084,237 2019 322,792 118,673 738 442,203
2009 609,652 41 0,436 9,126 1,029,214 Nov 2020 398,462 133,603 723 532,788
2010 829,406 445,679 8,453 1,283,538
Notes:
1) Excludes takeout policies ~ ITIZENS
PROPERTY INSURANCE CORPORATION
2) In 2006, there were 142,980 policies assumed from the Poe Financial Group included in Citizens' total policy count. As these policies remained on the Poe system at the end of that calendar
year, they a re not allocated at the account level.
Policy Count Trend
Citizens' Policy Count Trend
1,200,000
1,000,000
800,000
600,000
400,000
200,000
0
2013 2014 2015 2016 2017 2018 2019 2020 2021
Proje cted Proj ected
Citizens' Policy Count 1,021 ,694 661 ,161 503,865 455,843 440,406 427,397 442,203 532,135 630,257
I
Page 11
~ ITIZENS
PROPERTY INSURANCE CORPORATION
New Business Trends
Citizens’ Footprint: New-Business Trend (Aug-Nov 2019 Average vs. 2020)
Personal Residential Policy Types
Page 12
New Business Trends
Citizens’ Footprint: New-Business Trend (Aug-Nov 2019 Average vs. 2020)
Personal Residential Policy Types
Page 13
New Business Trends
Citizens’ Footprint: New-Business Trend (Aug-Nov 2019 Average vs. 2020)
Personal Residential Policy Types
Page 14
Financial Trends for Florida Domestic Insurers
Financial Trends for Florida Domestics
($000's Omitted)
$1 ,000,000
$750,000 • Net Income/Loss
• Net Underwriting Gain/Loss
11 II II --
$500,000
$250,000
$0
($250,000)
($500,000)
($750,000)
($1,000,000)
•1 I
($1,250,000)
($1,500,000)
2013 2014 2015 2016 2017 2018 2019 2020YTD
Net Income/Loss $347,337 $447,159 $462,668 ($1 3,772) ($142,445) ($150,696) ($372,269) ($727,361)
Net Underwriting Gain/Loss $416,01 0 $577,643 $532,630 ($194,112) ($426,472) ($414,266) ($725,099) ($1,260,208)
Page 15
~ ITIZENS
PROPERTY INSURANCE CORPORATION
Citizens Homeowners Rates Compared to Industry
91% of Citizens’ HO‐3
policies are charged
LESS than the
average
competitor’s rate.
Page 16
Citizens Rates
Prior to 2007, rates were required to be non-competitive with the private market.
Rates for personal and commercial residential policies were frozen by statute from January 1,
2007 through December 31, 2009.
Rates are now required to be actuarily sound, but not to exceed 10% increase annually per
policy, excluding the Florida Hurricane Catastrophe Fund Rapid Cash Build-Up Factor.
Citizens Board makes annual recommended rate changes to the Office of Insurance Regulation
(OIR) and they establish rates for Citizens.
Citizens is not required to purchase reinsurance at the same level as the private market is
required. Citizens provision for reinsurance is much lower than the private market, thus leading
to a lower rate need for Citizens. If Citizens needed the same level of reinsurance as a typical
private insurer then its Homeowners multiperil and wind-only indication would nearly triple.
Page 17 ~ ITIZ.~t!~
PROPERTY INSURAN
Citizens Rates
In December 2011, Citizens requested an outside legal opinion as to whether it was permissible
under Florida law to charge new policyholders the full actuarially indicated rates.
The outside legal opinion stated that “the applicable statutes and rating principles would
permit Citizens…to charge new policyholders the approved actuarially appropriate rate, while
applying the statutorily mandated limit on increases only to renewing policyholders.”
In July 2012 the Board decided not to move forward with asking the Office of Insurance
Regulation (OIR) to consider actuarially sound rates for new business.
In June 2020, Senator Jeff Brandes asked that Citizens again consider recommending to OIR that
new customers be charged the fully indicated actuarial rate.
In December 2020, Citizens requested OIR review the relevant statutes and legal opinions and
provide feedback on charging actuarially sound rates for new business.
Page 18 ~ ITIZ.~t!~
PROPERTY INSURAN
Citizens Rates
For Personal lines, charging actuarially sound rates for new business does not lead to across-the-
board higher rates for all new business policies.
In Personal Lines, 45.7% of current policies would see an average decrease of -3.0% if they were
charged the actuarially sound rate and 54.3% would have an average increase of 21.8%.
It is important to note that these changes are averages. For Personal Lines, there are outliers that
would have rate increases as high as 200%.
For Commercial, charging new business actuarially sounds rates would lead to mostly across-the-
board higher rates for new business. There are a few exceptions for Commercial Residential
Multiperil.
There would be some territories where the Commercial Residential Wind-Only rates would be
100% higher than the current rate.
Ultimately, Citizens recommends rate changes to the OIR, who make the final determination to
Citizens’ rate level. As in prior years, the rate filings submitted to the OIR will include all
information regarding the full indicated rates and the actual premium impact after application of
the 10% glide path.
Page 19 ~ ITIZ.~t!~
PROPERTY INSURAN
Clearinghouse
Carrier Participation
Policy Type Homeowners Homeowners Dwelling Condo Mobile Home
Company (Multiperil) (Wind-Only)
American Traditions X
Safe Harbor / Cabrillo X X X X
Capitol Preferred X
Edison X X
FedNat X X
Florida Peninsula X X
Heritage X
Monarch X
Southern Oak X X X X
UPC X
Weston X
Page 20
Clearinghouse
Initial Eligibility – Newly Purchased Home
Page 21
Clearinghouse
New Business Results
Received Offer % Deemed Deemed % Eligible
Ineligible Uninsurable
Policy Type Submissions but eligible for Receiving Ineligible Uninsurable For New
% %
Citizens Offer for Citizens with Citizens Policy
HO-3
250,576 21,359 8.52% 17,259 6.89% 2,754 1.10% 92.01%
New Business
Dwelling
55,992 343 0.61% 254 0.45% 618 1.10% 98.44%
New Business
HO-6
39,557 1,811 4.58% 1,703 4.31% 261 0.66% 95.04%
New Business
Wind Only
30,702 1,812 5.90% 2,994 9.75% 926 3.02% 87.23%
New Business
Mobile Home
10,874 295 2.71% 11 0.10% 176 1.62% 98.28%
New Business
Total 387,701 25,620 6.61% 22,221 5.73% 4,735 1.22% 93.05%
Page 22
Clearinghouse
Continuing Eligibility (Renewals)
Page 23
Clearinghouse
Policyholder Communication
Page 24
Clearinghouse
Renewal Results
Received Offer Deemed
% Receiving % Eligible to
Policy Type Submissions but eligible for Ineligible for Ineligible %
Offer Remain
Citizens Citizens
HO3 Renewals 130,521 1,195 0.92% 41 0.03% 99.97%
Dwelling Renewals 56,182 44 0.08% 2 0.00% 100.00%
Wind Only Renewals 32,863 769 2.34% 421 1.28% 98.72%
HO6 Renewals 26,416 280 1.06% 13 0.05% 99.95%
Mobile Home Renewals 25,633 0 0.00% 17 0.07% 99.93%
Total 271,615 2,288 0.84% 494 0.18% 99.82%
Page 25
Clearinghouse Submission and Outcome (Jan – Sept 2020)
Submission Results by Carrier (Volume)
400,000
350,000
300,000
250,000
200,000
150,000
100,000
50,000
-
Carrier A Carrier B Carrier C Carrier D Carrier E Carrier F Carrier G Carrier H Carrier I Carrier J Carrier K
Successful Offers No Offers Due to Underwriting Issues No Offers Due to Geographical Location Blocked Due to Agent Appointment (ONLY)
Page 26
Depopulation
Assumption Process Overview
Page 27
Depopulation
Policyholder Communication
Citizens will mail the Policyholder Choice packet to the policyholder approximately 48-days prior
to the assumption.
Page 28
Depopulation Policy Count Trend
Depopulation Policy Count Trend
450,000
400,000
350 ,000
300 ,000
250,000
200 ,000
150 ,000
100 ,000
50,000
2013 2014 2015 201 6 2017 2018 2019 2020 (Oct.)
I Depopulation Policy Count 365,833 416,453 272,596 88,000 34,008 17,902 10,084 4,653
Page 29
~ ITIZENS
PROPERTY INSURANCE CORPORATION
Depopulation
Past Successes
Citizens had more attractive polices (i.e., New Homes, No Claims, No Lapses in coverage,
better location)
Reinsurance was available and affordable
Financial position of participants was stronger
Policy premiums between Citizens and participating carriers was closer than today
Current Barriers to Takeout Participation
Due to prior depopulation efforts, majority of Citizens policies are not desirable to private
market (i.e., Older homes, multiple prior claims, location)
General financial weakness of prior or potential carrier participants
Due to lack of Citizens rate increases and the glidepath, Citizens premiums tend to be lower
than those offered by prior or potential carriers.
Page 30 ~ ITIZ.~t!~
PROPERTY INSURAN
Depopulation
Top Ten Prior Depopulation Participants
S&P Global Market Intelligence Data 3Q 2020
Financial Strength Surplus Direct Premiums Written Net Income
Depopulation 2013 - 2019
Rating ($000) ($000) ($000)
Policies AM Quarter YOY YTD YTD YOY YOY $ YTD YTD
Company Name Demotech 3Q 2020 2Q 2020
Tagged Best Change Change 3Q 2020 3Q 2019 Change Change 3Q 2020 3Q 2019
Heritage P&C
296,803 A (21%) $115,889 $146,601 17% $466,651 $399,171 (55%) ($15,428) ($43,522) ($28,094)
Insurance Co.
Safepoint
153,327 B- A 2% $45,017 $44,141 (1%) $115,434 $116,947 189% $11,104 $5,244 ($5,861)
Insurance Co.
Homeowners
92,395 A (8%) $128,095 $139,580 15% $304,650 $264,476 (307%) ($28,759) ($19,390) $9,369
Choice P&C Ins Co.
United P&C
86,758 A (17%) $137,131 $165,986 5% $623,588 $591,938 34% $11,130 ($21,795) ($32,925)
Insurance Co.
Southern Oak
67,356 A (8%) $42,296 $45,826 12% $89,922 $80,158 75% $5,164 ($1,743) ($6,907)
Insurance Co.
Weston Insurance
53,108 A (7%) $25,049 $26,860 21% $78,588 $64,835 (2035%) ($23,111) ($21,975) $1,136
Co.
Anchor P&C
50,760 (74%) $414 $1,603 (141%) ($21,547) $52,705 (22%) ($1,259) ($7,001) ($5,742)
Insurance Co.
Southern Fidelity
36,406 A 93% $60,662 $31,379 99% $280,247 $140,981 (252%) ($47,514) ($66,405) ($18,891)
Insurance Co
Olympus Insurance
31,970 A 3% $37,195 $36,271 10% $157,978 $143,754 (5%) ($141) $2,760 $2,901
Co.
First Community
25,771 B++ A (9%) $25,010 $27,335 22% $113,366 $92,547 (2080%) ($5,652) ($5,924) ($272)
Insurance Co.
Page 31
FSU Study:
Exposure Reduction and Depopulation Opportunities
In March 2020, Citizens Board of Governors engaged Florida State University (FSU) to conduct an
independent analysis to ensure Citizens is taking advantage of all opportunities to reduce
exposure and fulfill its mission as a residual market insurer.
FSU presented the results of the analysis at the December 2020 Board of Governors meeting with
recommendations and observations in the following general categories.
Initiatives Already Under Way by Citizens
• Depopulation and Clearinghouse Campaign
• Revise Citizens Mitigation Credits to better reflect exposure reduction
• Increase the use of inspections
• Further promote Citizens Managed Repair Program
• Continue with improved claims settlement practices
Potential Legislative Items (Examples)
• Require Alternative Dispute Resolution/Mediation
• Address Attorney Fee Multipliers
• Consider Changes to the One-Way Attorney Fee Statute
• Modify or eliminate Citizens Glidepath on Rates
• Apply provisions of the Assignment of Benefits law to first-party litigation
Page 32 ~ ITIZ.~t!~
PROPERTY INSURAN
FSU Study:
Exposure Reduction and Depopulation Opportunities
Recommendations within Citizens Current Statutory Purview
• Host workshops with Insurers, Investors and other stakeholders
• Create New Business Models
• Consider Financial Support for Mitigation
• Consider Policy Form Changes
Items for Referral to Third Parties for Consideration
• Strengthen the Statewide Building Code
• Create a Database for Florida Residential Properties
• Create a Statewide Fraud Database
• Revise Building Criteria in High-Risk Areas
• Create a New Industry Business Model
• Improve Overall Financial Solvency of the Florida Insurance Market
• Create a Statewide Program to Address Affordability of Property Insurance
Page 33 ~ ITIZ.~t!~
PROPERTY INSURAN
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