Insurers Urged To Consider Certain Areas of Concern Before Filing ‘Me Too’ Citizens Property Insurance Language
Apr 26, 2016
The Florida Office of Insurance Regulation (“OIR”) recently indicated that private insurance carriers could adopt the same language that had recently been approved for Citizens Property Insurance Corporation (“Citizens”) in regard to addressing claims challenges presented by assignment of benefits (“AOB”) issues.
Based upon discussion with OIR staff members, Colodny Fass is aware of other areas of concern, in addition to issues directly related to the Citizens AOB language, that could also be evaluated as part of the review of any insurer filings made to adopt the Citizens language.
While they should not be considered as all-inclusive, some of those areas are listed below. We suggest insurers give consideration to these issues if they intend to file a “me too” of Citizens’ AOB language.
- Outdated cancellation language – HB 165, SB 424, SB 708
- Outdated nonrenewal language – SB 424, SB 708
- Outdated concealment or fraud language – SB 708
- Existing damage exclusion issue
- Adopting Citizens language beyond the specific revisions made in the latest Citizens filing
- Eliminating necessary language from the submitting company’s form in an effort to add Citizens language
- Adding language that is more restrictive than Citizens
- Adding Citizens language without considering any ambiguities/conflicts/duplications that could result when integrated into the company’s existing language
- Endorsing an endorsement
- Citing Citizens form identifiers instead of the identifiers the submitting company uses
- Utilizing alpha or numeric characters that Citizens uses, but that do not correspond properly to the submitting company’s formatting style
- Typos that generate confusion for the policyholder
- Submitting language from an outdated Citizens strike & delete copy – Please refer to the “FINAL Strike & Delete Copy”
- Forgetting to renumber provisions when points are added or deleted
- Forgetting to update the table of contents as appropriate for changes in coverage titles or page numbers
Should you have any questions or comments, please contact Colodny Fass.
Click here to follow Colodny Fass on Twitter (@ColodnyFassLaw)
To unsubscribe from this newsletter, please send an e-mail to colodnyfassnews@gmail.com.