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"Information on Business Interruption Insurance"

Summary

A committee source document compiling material on business interruption insurance and COVID-19, led by a fact sheet from the Washington State Office of the Insurance Commissioner. The fact sheet reports an OIC data call finding that only two companies have policies covering COVID-19 claims, and explains physical-damage requirements, virus exclusions and the civil authority clause. It states that directing insurers to pay excluded claims is not within the commissioner's authority. The packet includes the office's Coronavirus and businesses web page, printed April 3, 2020, and an Insurance Information Institute article dated April 28, 2020. The article reports that industry policyholders' surplus dropped to $770 billion from $847 billion and warns of insurer impairment below $400 billion.

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OFFICE of the

INSURANCE
COMMISSIONER

WASHINGTON STATE

Information on Business Interruption
Insurance

What is business interruption insurance?

Business interruption insurance is not a standalone insurance policy. This type of coverage is offered
within, or attached to (referred to as a “rider"), a property insurance policy. Therefore, in order to trigger
the loss of income coverage, it requires the covered property to have incurred damage from a covered
peril that necessitated the business to suspend operations. Therefore, it focuses on actual physical
damage to the insurance property, often the place of business and/or its contents.

OIC survey

The Office of the Insurance Commissioner recently completed a special data call to our commercial
lines, regarding business interruption insurance coverage. Each insurer was asked to submit notices to
their own policyholders regarding how they view COVID-19 loss of income claims against that
policyholder’s own policy. Commercial policies can be customized much more than a typical
homeowner's policy so each individual commercial policy must be read to understand the coverage
each policy has.

Key information from OIC review

Only two companies have policies that cover COVID-19 claims. However, these two policies are NOT
designed for small retail businesses; they are geared for large companies with supply chains operating
in various locations.

All-risk and named peril policies

All of the remaining companies noted the property MUST be damaged by a covered peril to trigger
business interruption coverage. On “all-risk" policies, there must be direct physical loss or damage to a
covered property. This means that loss of income due to COVID-19 is not viewed as physically altering
the property to consider it damaged. On "named peril” policies, viruses is not a named peril, like fire,
explosion or lightning (which are typically listed).

Lonnie Johns-Brown | 360-725-7101 | LonnieJ@oic.wa.gov
Specific exclusions

In addition, most companies also attach a specific exclusion to their policies that prohibits coverage due
to virus. This specific policy exclusion has been used in the insurance industry since the mid-2000's, as a
result of the 2003 SARS outbreak. This exclusion is very clearly written that there is no coverage due to
loss in relation to a virus.

Civil authority clause

In the case of the government-forced closure of a business, there is a “civil authority” clause. However,
that clause only provides coverage when the government authority prohibits access due to a “covered
cause of loss.” Examples where the clause would apply are government-directed closures due to
flooding, wildfires or earthquakes. Since COVID-19 is NOT a covered cause of damage, there is no
coverage if the civil authority shuts down a business due to the COVID-19 outbreak. The virus exclusion

in the policy would also apply.

Policy endorsements

Some insurance companies offer endorsements that are added to a base insurance policy which offer
limited business income coverage relating to communicable disease that would cover some types of
COVID-19 claims. Such endorsements would be an additional cost above the base policy premium. For
the companies that offer such endorsements, it is not clear if they were offered to any business or only
to select types of businesses. It does appear we have a few of these types of endorsements in
Washington.

OIC’s authority

It is not within the insurance commissioner's regulatory authority, nor his emergency powers, to direct
insurance plans to pay for claims that are specifically not covered within an insured's policy. The
difficulty with directing insurance companies to pay for business interruption insurance on the basis of
the COVID-19 outbreak and resulting government-directed closures, is that the vast majority of policies
specifically exclude such coverage. Even more challenging is that private insurance, in general, is not
designed to cover something like COVID-19 business closures that are happening on such a large scale,
not just in Washington state, but throughout our entire country. The impact on insurance companies of
having to pay so many claims could destabilize the entire business property insurance industry and
could lead to insolvent companies unable to pay on claims.
Corsnavirus and businesses | Washington state Office of the Insurance Commissioner Page 1| of 4

OFFICE of the

INSURANCE
COMMISSIONER MENU

WASHINGTON STATE

For Consumers

Coronavirus and businesses

Information for Washington state businesses about coronavirus and its impact on commercial
insurance and business operations.

Ask us a question about coronavirus and business insurance (smartsheet,com)

What insurance do | need for my business to be
covered for losses due to coronavirus?

To be covered against a business’ loss of revenue due to a pandemic, such as coronavirus,

you would need to have purchased an insurance policy, or an endorsement for your policy that
covers such a loss before the outbreak started.

It's unlikely you'll be able to buy this coverage during the pandemic. After the pandemic is over

and the market has stabilized, you can contact your insurance agent or company to see if they
offer it.

If you need help understanding your policy, contact an insurance professional, like your
insurance agent or your insurance company. If you do not have a copy of your policy, ask your

agent or insurance company to send you the full policy, including all applicable endorsements
and declarations.

NOTE: The Office of the Insurance Commissioner does not have the authority to mandate
insurers sell or retroactively cover pandemic coverage or policy endorsements.

What if | already had a business policy that included
business interruption or business income coverage?
Will it cover my losses?

Business interruption and business income coverage protects your business against losses you
encounter when your business operations are suspended due to direct physical loss or

https://www.insurance.wa.gov/coronavirus-and-businesses 4/3/2020
Coronavirus and businesses | Washington state Office of the Insurance Commissioner Page 2°of 4

damage. An example is if your covered property was damaged by a fire and your business
must suspend operations until the covered property is repair or replaced. This type of policy
reimburses the revenue you lost while your business was interrupted.

It's questionable whether your business interruption or business income policy specifically
protects against coronavirus. It’s important to read your policy for all exclusions, coverage
limits, and deductibles.

Will my business policy cover my business’ loss of
revenue because of a government closure due to
coronavirus?

There is a clause in most business policies called "Civil Authority," which addresses the
situation when government prohibits access to your business. If your policy requires a “covered
cause of loss” to be the reason why the civil authority restricted access to your business, your
insurance company would need to determine if the coronavirus outbreak is a covered cause of
loss. Some business policies do not have this requirement. Please read your policy carefully.

Your insurer’s responsibility if you file a claim

If you file a claim with your insurance company, it must conduct a reasonable investigation. If it
denies your claim, it must inform you of the specific language in the policy that denies
coverage. If you need more information or have questions, contact your insurance agent or

company.

lf | have sick employees due to coronavirus and have
to temporarily close my business, will my business
policy cover me?

Business policies can vary depending on what's included in your coverage. We recommend
you check with your insurance agent or company to see if your policy covers an employee
availability due to epidemic or pandemic. Typically business policies cover business closures
for events such as fire, a burst pipe, or a windstorm.

Small Business Administration and disaster assistance

The U.S, Small Business Administration (www.sba.gov) is offering low-interest federal disaster
loans for working capital to small businesses suffering substantial economic injury due
to coronavirus.

If you don't have a online access, call the Small Business Administration at 800-659- 3955.

https://www.insurance.wa.gov/coronavirus-and-businesses 4/3/2020
The True Cost of Rewriting Business Income (Interruption) Policies | III Page 1 of 2

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The True Cost of Rewriting Business
Income (Interruption) Policies

Business Insurance

April 28, 2020 The True Cost of Rewriting
Business Income (Interruption) Policies
SHARE THIS
COVID-19 has brought the U.S. economy to a standstill.
f YW @ in

Are U.S. insurers so well-capitalized they can pay claims on insure
policies for which they collected no premiums due to virus and
bacteria exclusions?

The short answer is no.
DOWNLOAD TO PDF

Industry’s 2020 Surplus

U.S. auto, home, and business insurers
saw its policyholdars’ surplus—the

cumulative value of their assets, minus
its liabilities—drop to $770 billion fiom
$847 billion in 2020's first quartet. 20 sips.

3/2020 surplus

The surplus is set aside to pay claims ns — pecans
resulting from covered events that caus? $0 $100 $200 $300 $400 $500 $600 $700 $200 $9¢
direct physical damage lo property, such Billions

as fires, lornadaes and hurdcanes. When
industry surplus drops below $400 billion,
dozens, perhaps hundreds, of insurers
will b= imperiled.

Projected Surplus Depletion lo businesses nationwide, no matter what insurance
policies they have—would cost the insurance industr

Mandating business income payouls to businesses hundreds of billions of dollars a month.

that incurred no direct physical propery damage—or

Retroactive business income (Bl) scenario for small- and medium-sized enterprises (SMEs)

Virus/Bacteria Exclusion Removal Higher
Median
Lower
Expanded BI to all SMEs Higher
Median
Lower

$250

$125

$0 © $50. $00.—S«SISD—S«=«$200—=S«$250-=«$300«« $50 SAC
Monthly Claims (Billions)

» INSURANCE
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https://www.iii.org/article/the-true-cost-of-rewriting-business-income-interruption-policies... 4/30/2020
The True Cost of Rewriting Business Income (Interruption) Policies | LI Page 2 of 2

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https://www.iii.org/article/the-true-cost-of-rewriting-business-income-interruption-policies... 4/30/2020

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